Finding 2024-004 U.S. Department of Treasury Federal Award Year Ending June 30, 2024 COVID-19: Coronavirus State and Local Fiscal Recovery Funds Lack of internal controls over the preparation of the Schedule of Expenditures of Federal Awards 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. Condition: The Schedule of Expenditures for Federal Awards for the year ended June 30, 2024, was initially overstated by $529,900 due to an improper subrecipient verses beneficiary determination for a grant. Cause: While this original grant agreement specified that the Foundation was a subrecipient, the Foundation did not timely review a 2024 grant amendment or obtain further correspondence from the granter that updated the initial subrecipient determination to now identify the Foundation as a beneficiary, resulting in the removal of $529,900 from the Schedule of Expenditures for Federal Awards. Effect or potential effect: Improper reporting of federal expenditures results in errors on the Schedule of Expenditures for Federal Awards and can lead to inaccurate major program determination. In this instance, the error did result in an update to the major program determination. Questioned costs: None. Context: During the audit, we reviewed a July 2024 grant amendment from the grantor that removed a number of the original grant requirements and reclassified the Foundation as a “grantee.” Upon further inquiry with the grantor, it was discovered that the Foundation is no longer considered a subrecipient. Thus, the Foundation is a beneficiary, which resulted in the removal of incurred costs of $529,900 from the Schedule of Expenditures of Federal Awards. Recommendation: To ensure accuracy of the Schedule of Expenditures of Federal Awards, the Foundation should improve the processes and controls around timely identification of potential federal awards, which includes enhancing the review of any grant amendments and timely contacting passthrough entities to verify potential updates to the subrecipient verses beneficiary determination. Views of responsible officials of the auditee: The Foundation agrees with the above finding, and its response is included in the corrective action plan.
Assistance Listing Number, Federal Agency, and Program Name 84.425D, U.S. Department of Education, Education Stabilization Fund COVID 19 ESSER II Formula Fund II and 98c Learning Loss, and 84.425U, COVID 19 ESSER Education Equity Fund III Federal Award Identification Number and Year 213712, 213782, 213713, 2023 Pass through Entity Michigan Department of Education Finding Type Material weakness Criteria Per 2 CFR 200.510(b) and Section 500.508(b) of Title 2, Subtitle A, Chapter II, Part 200, Subpart F, auditees 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 Section 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 The schedule of expenditures of federal awards (SEFA) contained inaccuracies and incomplete information that was identified during the audit. Questioned Costs None Identification of How Questioned Costs Were Computed N/A Context Multiple grants were presented inaccurately from the SEFA prepared by management in federal payments received and expenditures reported, which was identified by the auditor during the annual audit and subsequently corrected on the SEFA. The inaccuracies was a combination of amounts recorded in the School District's ledger that were incorrectly reflected on the SEFA, and amounts that required adjustment in the School District's ledger and also on the SEFA that was identified in the course of the audit. Cause and Effect The School District did not have sufficient controls in place to properly reconcile federal revenue to the federal expenditures reflected on the SEFA to validate that all federal grants awarded and expended were included in the SEFA and presented accurately. Recommendation The School District should implement a process to ensure that the SEFA is prepared timely and that all grant expenditures are included accurately. Views of Responsible Officials and Corrective Action Plan The School District will develop a SEFA checklist to help ensure all federal expenditures are properly reported. Additional processes will be put in place by management to review the SEFA in advance of the annual audit to effectively meet audit report timelines and help ensure completeness, validity, and accuracy of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name 84.425D, U.S. Department of Education, Education Stabilization Fund COVID 19 ESSER II Formula Fund II and 98c Learning Loss, and 84.425U, COVID 19 ESSER Education Equity Fund III Federal Award Identification Number and Year 213712, 213782, 213713, 2023 Pass through Entity Michigan Department of Education Finding Type Material weakness Criteria Per 2 CFR 200.510(b) and Section 500.508(b) of Title 2, Subtitle A, Chapter II, Part 200, Subpart F, auditees 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 Section 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 The schedule of expenditures of federal awards (SEFA) contained inaccuracies and incomplete information that was identified during the audit. Questioned Costs None Identification of How Questioned Costs Were Computed N/A Context Multiple grants were presented inaccurately from the SEFA prepared by management in federal payments received and expenditures reported, which was identified by the auditor during the annual audit and subsequently corrected on the SEFA. The inaccuracies was a combination of amounts recorded in the School District's ledger that were incorrectly reflected on the SEFA, and amounts that required adjustment in the School District's ledger and also on the SEFA that was identified in the course of the audit. Cause and Effect The School District did not have sufficient controls in place to properly reconcile federal revenue to the federal expenditures reflected on the SEFA to validate that all federal grants awarded and expended were included in the SEFA and presented accurately. Recommendation The School District should implement a process to ensure that the SEFA is prepared timely and that all grant expenditures are included accurately. Views of Responsible Officials and Corrective Action Plan The School District will develop a SEFA checklist to help ensure all federal expenditures are properly reported. Additional processes will be put in place by management to review the SEFA in advance of the annual audit to effectively meet audit report timelines and help ensure completeness, validity, and accuracy of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name 84.425D, U.S. Department of Education, Education Stabilization Fund COVID 19 ESSER II Formula Fund II and 98c Learning Loss, and 84.425U, COVID 19 ESSER Education Equity Fund III Federal Award Identification Number and Year 213712, 213782, 213713, 2023 Pass through Entity Michigan Department of Education Finding Type Material weakness Criteria Per 2 CFR 200.510(b) and Section 500.508(b) of Title 2, Subtitle A, Chapter II, Part 200, Subpart F, auditees 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 Section 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 The schedule of expenditures of federal awards (SEFA) contained inaccuracies and incomplete information that was identified during the audit. Questioned Costs None Identification of How Questioned Costs Were Computed N/A Context Multiple grants were presented inaccurately from the SEFA prepared by management in federal payments received and expenditures reported, which was identified by the auditor during the annual audit and subsequently corrected on the SEFA. The inaccuracies was a combination of amounts recorded in the School District's ledger that were incorrectly reflected on the SEFA, and amounts that required adjustment in the School District's ledger and also on the SEFA that was identified in the course of the audit. Cause and Effect The School District did not have sufficient controls in place to properly reconcile federal revenue to the federal expenditures reflected on the SEFA to validate that all federal grants awarded and expended were included in the SEFA and presented accurately. Recommendation The School District should implement a process to ensure that the SEFA is prepared timely and that all grant expenditures are included accurately. Views of Responsible Officials and Corrective Action Plan The School District will develop a SEFA checklist to help ensure all federal expenditures are properly reported. Additional processes will be put in place by management to review the SEFA in advance of the annual audit to effectively meet audit report timelines and help ensure completeness, validity, and accuracy of the final SEFA reporting.
Item 2024-007: Schedule of expenditures of federal awards presentation Federal Agency: U.S. Department of Housing and Urban Development; U.S. Department of Treasury Program: HOME Investment Partnerships Program (ALN 14.239); Housing Trust Fund (ALN 14.275); COVID-19 - Emergency Rental Assistance (ALN 21.023); Homeowner Assistance Fund Program (ALN 21.026) Pass-through Entity: None Federal Assistance Identification Number or Pass-Through Number: None Federal Award Year: Year ended June 30, 2024 Type of Finding: Material Weakness in Internal Control over Compliance Criteria: The Agency is required to comply with 2 CFR section 200.510(b) which requires 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 section 200.502. Further, the Agency is required to comply with 2 CFR 200.512 which requires that the information included in the reporting package is accurate and complete. Condition: We noted the following errors in the original SEFA we received for the audit: Loans provided under the HOME Investment Partnerships Program (ALN 14.239) were understated by $8,641,271 Loans provided under the Housing Trust Fund (ALN 14.275) were understated by $4,466,122 Expenditures under the Emergency Rental Assistance Program (ALN 21.023) were understated by $382,418 Expenditures under the COVID-19—Homeowner Assistance Fund Program (ALN 21.026) are overstated $403,795 Expenditures under the COVID-19—HOME Investment Partnerships Program, American Rescue Plan (ALN 14.239) are overstated $99,928 Cause: There was a breakdown in the Agency’s procedures related to preparation and review of the SEFA. The Agency’s procedures for preparing the SEFA did not account for classification of certain loans subject to continuing compliance requirements. The errors of $8,641,271 related to ALN 14.239 and $4,466,122 related to ALN 14.275 were caused by the Agency not properly identifying certain loans required to be included on the SEFA. The error of $382,418 related to ALN 21.023 was caused by the Agency reducing a subscription software disbursement by the portion of the disbursement related to payments on the subscription liability. The errors of $403,795 and $99,928 related to ALN 21.026 and ALN 14.239, respectively, were caused by the Agency charging certain direct and indirect costs from fiscal year 2021, 2022, and 2023 to the programs in fiscal year 2024. Effect: The Agency adjusted its fiscal year 2024 SEFA by $13,489,811 for the errors related to ALN 14.239, 14.275, and 21.023. The expenditures for ALN 21.026 and 14.239 are overstated $403,795 and $99,928, respectively. Questioned Costs: None Context: The Agency’s expenditures of federal awards reported on the SEFA were understated by $13,489,811 which was corrected during the audit. The Agency’s expenditures of federal awards reported on the SEFA for ALN 21.026 and ALN 14.239 are overstated $403,795 and $99,928, respectively, which the Agency did not correct. Total expenditures reported on the SEFA, as adjusted for this matter, are $422,678,239. Repeat Finding?: No Recommendation: We recommend that the Agency review and strengthen its processes and controls over the preparation of the SEFA. Views of responsible officials of the auditee: We agree with the above finding and our response is included in the corrective action plan.
Item 2024-008: Allowable Costs Federal Agency: U.S. Department of Housing and Urban Development; U.S. Department of Treasury Program: COVID-19—HOME Investment Partnerships Program, American Rescue Plan (ALN 14.239); COVID-19 - Emergency Rental Assistance (ALN 21.023); COVID-19—Homeowner Assistance Fund Program (ALN 21.026) Pass-through Entity: None Federal Assistance Identification Number or Pass-Through Number: None Federal Award Year: Year ended June 30, 2024 Type of Finding: Compliance Finding and Material Weakness in Internal Control over Compliance Criteria: The Agency is required to comply with 2 CFR 200.502 which states, “The determination of when a Federal award is expended must be based on when the activity related to the Federal award occurs.” The Agency is also required to comply with 2 CFR 200.403 which indicates that allowable costs must be determined in accordance with accounting principles generally accepted in the United States of America (GAAP). Appendix VII to 2 CFR 200—State/Local Government and Indian Tribe-Wide Central Service Cost Allocation Plans 2 states, “Indirect cost rates will be reviewed, negotiated, and approved by the cognizant agency on a timely basis. Once a rate has been agreed upon, it will be accepted and used by all Federal agencies unless prohibited or limited by statute. Where a Federal awarding agency has reason to believe that special operating factors affecting its Federal awards necessitate special indirect cost rates, the funding agency will, prior to the time the rates are negotiated, notify the cognizant agency for indirect costs.” Condition: We noted the Agency charged $119,169 of direct and indirect costs from fiscal year 2021 and 2022, and direct costs from fiscal year 2023 to COVID-19—HOME Investment Partnerships Program, American Rescue Plan (ALN 14.239) in fiscal year 2024. We noted the Agency charged $426,504 of direct costs from fiscal year 2021 through 2023 to COVID-19 - Emergency Rental Assistance (ALN 21.023). We noted the Agency charged $1,153,427 of direct costs from fiscal year 2021 through 2023 to COVID-19—Homeowner Assistance Fund Program (ALN 21.026) in fiscal year 2024. These costs do not meet the allowable cost criteria as they were not determined in accordance with GAAP which requires expenses to be recorded when incurred. The Agency had an approved indirect cost rate which allowed them to charge the indirect costs in those previous fiscal years. Cause: The Agency incorrectly charged direct and indirect costs in fiscal year 2024 that were incurred in previous fiscal years for the programs noted above. Effect: The Agency inappropriately charged the above federal programs for direct and indirect costs in fiscal year 2024. During the audit, the Agency reevaluated its direct and indirect costs incurred in previous years that were charged in fiscal year 2024. The Agency identified additional direct and indirect costs incurred in fiscal year 2024 that were eligible to be charged to ALN 14.239, ALN 21.023, and ALN 21.026 which were not previously charged to the program to offset a portion of the errors identified above. This resulted in the expenditures charged to ALN 14.239, ALN 21.023, and ALN 21.026 being overstated by $99,928, $0, and $403,795, respectively. Questioned Costs: ALN 14.239 – $119,169; ALN 21.023 – $426,504; ALN 21.026 – $1,153,427; Total – $1,699,100 Context: The Agency’s expenditures of federal awards charged to ALN 14.239, ALN 21.023 and ALN 21.026 were overstated $119,169, $426,504, and $1,153,427, respectively. During the audit, the Agency identified additional direct and indirect costs incurred in fiscal year 2024 that were eligible to be charged to ALN 14.239, ALN 21.023, and ALN 21.026 which were not previously charged to the program which resulted in the expenditures charged to ALN 14.239, ALN 21.023, and ALN 21.026 being overstated by $99,928, $0, and $403,795, respectively. The total expenditures for ALN 14.239, ALN 21.023, and ALN 21.026 are $81,364,920, $41,673,294, and $14,339,711, respectively. Repeat Finding?: No Recommendation: The Agency should charge direct and indirect costs to federal programs in the year the costs are incurred and using its approved indirect cost rate. Views of responsible officials of the auditee: We agree with the above finding and our response is included in the corrective action plan.
Item 2024-007: Schedule of expenditures of federal awards presentation Federal Agency: U.S. Department of Housing and Urban Development; U.S. Department of Treasury Program: HOME Investment Partnerships Program (ALN 14.239); Housing Trust Fund (ALN 14.275); COVID-19 - Emergency Rental Assistance (ALN 21.023); Homeowner Assistance Fund Program (ALN 21.026) Pass-through Entity: None Federal Assistance Identification Number or Pass-Through Number: None Federal Award Year: Year ended June 30, 2024 Type of Finding: Material Weakness in Internal Control over Compliance Criteria: The Agency is required to comply with 2 CFR section 200.510(b) which requires 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 section 200.502. Further, the Agency is required to comply with 2 CFR 200.512 which requires that the information included in the reporting package is accurate and complete. Condition: We noted the following errors in the original SEFA we received for the audit: Loans provided under the HOME Investment Partnerships Program (ALN 14.239) were understated by $8,641,271 Loans provided under the Housing Trust Fund (ALN 14.275) were understated by $4,466,122 Expenditures under the Emergency Rental Assistance Program (ALN 21.023) were understated by $382,418 Expenditures under the COVID-19—Homeowner Assistance Fund Program (ALN 21.026) are overstated $403,795 Expenditures under the COVID-19—HOME Investment Partnerships Program, American Rescue Plan (ALN 14.239) are overstated $99,928 Cause: There was a breakdown in the Agency’s procedures related to preparation and review of the SEFA. The Agency’s procedures for preparing the SEFA did not account for classification of certain loans subject to continuing compliance requirements. The errors of $8,641,271 related to ALN 14.239 and $4,466,122 related to ALN 14.275 were caused by the Agency not properly identifying certain loans required to be included on the SEFA. The error of $382,418 related to ALN 21.023 was caused by the Agency reducing a subscription software disbursement by the portion of the disbursement related to payments on the subscription liability. The errors of $403,795 and $99,928 related to ALN 21.026 and ALN 14.239, respectively, were caused by the Agency charging certain direct and indirect costs from fiscal year 2021, 2022, and 2023 to the programs in fiscal year 2024. Effect: The Agency adjusted its fiscal year 2024 SEFA by $13,489,811 for the errors related to ALN 14.239, 14.275, and 21.023. The expenditures for ALN 21.026 and 14.239 are overstated $403,795 and $99,928, respectively. Questioned Costs: None Context: The Agency’s expenditures of federal awards reported on the SEFA were understated by $13,489,811 which was corrected during the audit. The Agency’s expenditures of federal awards reported on the SEFA for ALN 21.026 and ALN 14.239 are overstated $403,795 and $99,928, respectively, which the Agency did not correct. Total expenditures reported on the SEFA, as adjusted for this matter, are $422,678,239. Repeat Finding?: No Recommendation: We recommend that the Agency review and strengthen its processes and controls over the preparation of the SEFA. Views of responsible officials of the auditee: We agree with the above finding and our response is included in the corrective action plan.
Item 2024-008: Allowable Costs Federal Agency: U.S. Department of Housing and Urban Development; U.S. Department of Treasury Program: COVID-19—HOME Investment Partnerships Program, American Rescue Plan (ALN 14.239); COVID-19 - Emergency Rental Assistance (ALN 21.023); COVID-19—Homeowner Assistance Fund Program (ALN 21.026) Pass-through Entity: None Federal Assistance Identification Number or Pass-Through Number: None Federal Award Year: Year ended June 30, 2024 Type of Finding: Compliance Finding and Material Weakness in Internal Control over Compliance Criteria: The Agency is required to comply with 2 CFR 200.502 which states, “The determination of when a Federal award is expended must be based on when the activity related to the Federal award occurs.” The Agency is also required to comply with 2 CFR 200.403 which indicates that allowable costs must be determined in accordance with accounting principles generally accepted in the United States of America (GAAP). Appendix VII to 2 CFR 200—State/Local Government and Indian Tribe-Wide Central Service Cost Allocation Plans 2 states, “Indirect cost rates will be reviewed, negotiated, and approved by the cognizant agency on a timely basis. Once a rate has been agreed upon, it will be accepted and used by all Federal agencies unless prohibited or limited by statute. Where a Federal awarding agency has reason to believe that special operating factors affecting its Federal awards necessitate special indirect cost rates, the funding agency will, prior to the time the rates are negotiated, notify the cognizant agency for indirect costs.” Condition: We noted the Agency charged $119,169 of direct and indirect costs from fiscal year 2021 and 2022, and direct costs from fiscal year 2023 to COVID-19—HOME Investment Partnerships Program, American Rescue Plan (ALN 14.239) in fiscal year 2024. We noted the Agency charged $426,504 of direct costs from fiscal year 2021 through 2023 to COVID-19 - Emergency Rental Assistance (ALN 21.023). We noted the Agency charged $1,153,427 of direct costs from fiscal year 2021 through 2023 to COVID-19—Homeowner Assistance Fund Program (ALN 21.026) in fiscal year 2024. These costs do not meet the allowable cost criteria as they were not determined in accordance with GAAP which requires expenses to be recorded when incurred. The Agency had an approved indirect cost rate which allowed them to charge the indirect costs in those previous fiscal years. Cause: The Agency incorrectly charged direct and indirect costs in fiscal year 2024 that were incurred in previous fiscal years for the programs noted above. Effect: The Agency inappropriately charged the above federal programs for direct and indirect costs in fiscal year 2024. During the audit, the Agency reevaluated its direct and indirect costs incurred in previous years that were charged in fiscal year 2024. The Agency identified additional direct and indirect costs incurred in fiscal year 2024 that were eligible to be charged to ALN 14.239, ALN 21.023, and ALN 21.026 which were not previously charged to the program to offset a portion of the errors identified above. This resulted in the expenditures charged to ALN 14.239, ALN 21.023, and ALN 21.026 being overstated by $99,928, $0, and $403,795, respectively. Questioned Costs: ALN 14.239 – $119,169; ALN 21.023 – $426,504; ALN 21.026 – $1,153,427; Total – $1,699,100 Context: The Agency’s expenditures of federal awards charged to ALN 14.239, ALN 21.023 and ALN 21.026 were overstated $119,169, $426,504, and $1,153,427, respectively. During the audit, the Agency identified additional direct and indirect costs incurred in fiscal year 2024 that were eligible to be charged to ALN 14.239, ALN 21.023, and ALN 21.026 which were not previously charged to the program which resulted in the expenditures charged to ALN 14.239, ALN 21.023, and ALN 21.026 being overstated by $99,928, $0, and $403,795, respectively. The total expenditures for ALN 14.239, ALN 21.023, and ALN 21.026 are $81,364,920, $41,673,294, and $14,339,711, respectively. Repeat Finding?: No Recommendation: The Agency should charge direct and indirect costs to federal programs in the year the costs are incurred and using its approved indirect cost rate. Views of responsible officials of the auditee: We agree with the above finding and our response is included in the corrective action plan.
Item 2024-007: Schedule of expenditures of federal awards presentation Federal Agency: U.S. Department of Housing and Urban Development; U.S. Department of Treasury Program: HOME Investment Partnerships Program (ALN 14.239); Housing Trust Fund (ALN 14.275); COVID-19 - Emergency Rental Assistance (ALN 21.023); Homeowner Assistance Fund Program (ALN 21.026) Pass-through Entity: None Federal Assistance Identification Number or Pass-Through Number: None Federal Award Year: Year ended June 30, 2024 Type of Finding: Material Weakness in Internal Control over Compliance Criteria: The Agency is required to comply with 2 CFR section 200.510(b) which requires 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 section 200.502. Further, the Agency is required to comply with 2 CFR 200.512 which requires that the information included in the reporting package is accurate and complete. Condition: We noted the following errors in the original SEFA we received for the audit: Loans provided under the HOME Investment Partnerships Program (ALN 14.239) were understated by $8,641,271 Loans provided under the Housing Trust Fund (ALN 14.275) were understated by $4,466,122 Expenditures under the Emergency Rental Assistance Program (ALN 21.023) were understated by $382,418 Expenditures under the COVID-19—Homeowner Assistance Fund Program (ALN 21.026) are overstated $403,795 Expenditures under the COVID-19—HOME Investment Partnerships Program, American Rescue Plan (ALN 14.239) are overstated $99,928 Cause: There was a breakdown in the Agency’s procedures related to preparation and review of the SEFA. The Agency’s procedures for preparing the SEFA did not account for classification of certain loans subject to continuing compliance requirements. The errors of $8,641,271 related to ALN 14.239 and $4,466,122 related to ALN 14.275 were caused by the Agency not properly identifying certain loans required to be included on the SEFA. The error of $382,418 related to ALN 21.023 was caused by the Agency reducing a subscription software disbursement by the portion of the disbursement related to payments on the subscription liability. The errors of $403,795 and $99,928 related to ALN 21.026 and ALN 14.239, respectively, were caused by the Agency charging certain direct and indirect costs from fiscal year 2021, 2022, and 2023 to the programs in fiscal year 2024. Effect: The Agency adjusted its fiscal year 2024 SEFA by $13,489,811 for the errors related to ALN 14.239, 14.275, and 21.023. The expenditures for ALN 21.026 and 14.239 are overstated $403,795 and $99,928, respectively. Questioned Costs: None Context: The Agency’s expenditures of federal awards reported on the SEFA were understated by $13,489,811 which was corrected during the audit. The Agency’s expenditures of federal awards reported on the SEFA for ALN 21.026 and ALN 14.239 are overstated $403,795 and $99,928, respectively, which the Agency did not correct. Total expenditures reported on the SEFA, as adjusted for this matter, are $422,678,239. Repeat Finding?: No Recommendation: We recommend that the Agency review and strengthen its processes and controls over the preparation of the SEFA. Views of responsible officials of the auditee: We agree with the above finding and our response is included in the corrective action plan.
Item 2024-007: Schedule of expenditures of federal awards presentation Federal Agency: U.S. Department of Housing and Urban Development; U.S. Department of Treasury Program: HOME Investment Partnerships Program (ALN 14.239); Housing Trust Fund (ALN 14.275); COVID-19 - Emergency Rental Assistance (ALN 21.023); Homeowner Assistance Fund Program (ALN 21.026) Pass-through Entity: None Federal Assistance Identification Number or Pass-Through Number: None Federal Award Year: Year ended June 30, 2024 Type of Finding: Material Weakness in Internal Control over Compliance Criteria: The Agency is required to comply with 2 CFR section 200.510(b) which requires 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 section 200.502. Further, the Agency is required to comply with 2 CFR 200.512 which requires that the information included in the reporting package is accurate and complete. Condition: We noted the following errors in the original SEFA we received for the audit: Loans provided under the HOME Investment Partnerships Program (ALN 14.239) were understated by $8,641,271 Loans provided under the Housing Trust Fund (ALN 14.275) were understated by $4,466,122 Expenditures under the Emergency Rental Assistance Program (ALN 21.023) were understated by $382,418 Expenditures under the COVID-19—Homeowner Assistance Fund Program (ALN 21.026) are overstated $403,795 Expenditures under the COVID-19—HOME Investment Partnerships Program, American Rescue Plan (ALN 14.239) are overstated $99,928 Cause: There was a breakdown in the Agency’s procedures related to preparation and review of the SEFA. The Agency’s procedures for preparing the SEFA did not account for classification of certain loans subject to continuing compliance requirements. The errors of $8,641,271 related to ALN 14.239 and $4,466,122 related to ALN 14.275 were caused by the Agency not properly identifying certain loans required to be included on the SEFA. The error of $382,418 related to ALN 21.023 was caused by the Agency reducing a subscription software disbursement by the portion of the disbursement related to payments on the subscription liability. The errors of $403,795 and $99,928 related to ALN 21.026 and ALN 14.239, respectively, were caused by the Agency charging certain direct and indirect costs from fiscal year 2021, 2022, and 2023 to the programs in fiscal year 2024. Effect: The Agency adjusted its fiscal year 2024 SEFA by $13,489,811 for the errors related to ALN 14.239, 14.275, and 21.023. The expenditures for ALN 21.026 and 14.239 are overstated $403,795 and $99,928, respectively. Questioned Costs: None Context: The Agency’s expenditures of federal awards reported on the SEFA were understated by $13,489,811 which was corrected during the audit. The Agency’s expenditures of federal awards reported on the SEFA for ALN 21.026 and ALN 14.239 are overstated $403,795 and $99,928, respectively, which the Agency did not correct. Total expenditures reported on the SEFA, as adjusted for this matter, are $422,678,239. Repeat Finding?: No Recommendation: We recommend that the Agency review and strengthen its processes and controls over the preparation of the SEFA. Views of responsible officials of the auditee: We agree with the above finding and our response is included in the corrective action plan.
Item 2024-008: Allowable Costs Federal Agency: U.S. Department of Housing and Urban Development; U.S. Department of Treasury Program: COVID-19—HOME Investment Partnerships Program, American Rescue Plan (ALN 14.239); COVID-19 - Emergency Rental Assistance (ALN 21.023); COVID-19—Homeowner Assistance Fund Program (ALN 21.026) Pass-through Entity: None Federal Assistance Identification Number or Pass-Through Number: None Federal Award Year: Year ended June 30, 2024 Type of Finding: Compliance Finding and Material Weakness in Internal Control over Compliance Criteria: The Agency is required to comply with 2 CFR 200.502 which states, “The determination of when a Federal award is expended must be based on when the activity related to the Federal award occurs.” The Agency is also required to comply with 2 CFR 200.403 which indicates that allowable costs must be determined in accordance with accounting principles generally accepted in the United States of America (GAAP). Appendix VII to 2 CFR 200—State/Local Government and Indian Tribe-Wide Central Service Cost Allocation Plans 2 states, “Indirect cost rates will be reviewed, negotiated, and approved by the cognizant agency on a timely basis. Once a rate has been agreed upon, it will be accepted and used by all Federal agencies unless prohibited or limited by statute. Where a Federal awarding agency has reason to believe that special operating factors affecting its Federal awards necessitate special indirect cost rates, the funding agency will, prior to the time the rates are negotiated, notify the cognizant agency for indirect costs.” Condition: We noted the Agency charged $119,169 of direct and indirect costs from fiscal year 2021 and 2022, and direct costs from fiscal year 2023 to COVID-19—HOME Investment Partnerships Program, American Rescue Plan (ALN 14.239) in fiscal year 2024. We noted the Agency charged $426,504 of direct costs from fiscal year 2021 through 2023 to COVID-19 - Emergency Rental Assistance (ALN 21.023). We noted the Agency charged $1,153,427 of direct costs from fiscal year 2021 through 2023 to COVID-19—Homeowner Assistance Fund Program (ALN 21.026) in fiscal year 2024. These costs do not meet the allowable cost criteria as they were not determined in accordance with GAAP which requires expenses to be recorded when incurred. The Agency had an approved indirect cost rate which allowed them to charge the indirect costs in those previous fiscal years. Cause: The Agency incorrectly charged direct and indirect costs in fiscal year 2024 that were incurred in previous fiscal years for the programs noted above. Effect: The Agency inappropriately charged the above federal programs for direct and indirect costs in fiscal year 2024. During the audit, the Agency reevaluated its direct and indirect costs incurred in previous years that were charged in fiscal year 2024. The Agency identified additional direct and indirect costs incurred in fiscal year 2024 that were eligible to be charged to ALN 14.239, ALN 21.023, and ALN 21.026 which were not previously charged to the program to offset a portion of the errors identified above. This resulted in the expenditures charged to ALN 14.239, ALN 21.023, and ALN 21.026 being overstated by $99,928, $0, and $403,795, respectively. Questioned Costs: ALN 14.239 – $119,169; ALN 21.023 – $426,504; ALN 21.026 – $1,153,427; Total – $1,699,100 Context: The Agency’s expenditures of federal awards charged to ALN 14.239, ALN 21.023 and ALN 21.026 were overstated $119,169, $426,504, and $1,153,427, respectively. During the audit, the Agency identified additional direct and indirect costs incurred in fiscal year 2024 that were eligible to be charged to ALN 14.239, ALN 21.023, and ALN 21.026 which were not previously charged to the program which resulted in the expenditures charged to ALN 14.239, ALN 21.023, and ALN 21.026 being overstated by $99,928, $0, and $403,795, respectively. The total expenditures for ALN 14.239, ALN 21.023, and ALN 21.026 are $81,364,920, $41,673,294, and $14,339,711, respectively. Repeat Finding?: No Recommendation: The Agency should charge direct and indirect costs to federal programs in the year the costs are incurred and using its approved indirect cost rate. Views of responsible officials of the auditee: We agree with the above finding and our response is included in the corrective action plan.
Item 2024-007: Schedule of expenditures of federal awards presentation Federal Agency: U.S. Department of Housing and Urban Development; U.S. Department of Treasury Program: HOME Investment Partnerships Program (ALN 14.239); Housing Trust Fund (ALN 14.275); COVID-19 - Emergency Rental Assistance (ALN 21.023); Homeowner Assistance Fund Program (ALN 21.026) Pass-through Entity: None Federal Assistance Identification Number or Pass-Through Number: None Federal Award Year: Year ended June 30, 2024 Type of Finding: Material Weakness in Internal Control over Compliance Criteria: The Agency is required to comply with 2 CFR section 200.510(b) which requires 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 section 200.502. Further, the Agency is required to comply with 2 CFR 200.512 which requires that the information included in the reporting package is accurate and complete. Condition: We noted the following errors in the original SEFA we received for the audit: Loans provided under the HOME Investment Partnerships Program (ALN 14.239) were understated by $8,641,271 Loans provided under the Housing Trust Fund (ALN 14.275) were understated by $4,466,122 Expenditures under the Emergency Rental Assistance Program (ALN 21.023) were understated by $382,418 Expenditures under the COVID-19—Homeowner Assistance Fund Program (ALN 21.026) are overstated $403,795 Expenditures under the COVID-19—HOME Investment Partnerships Program, American Rescue Plan (ALN 14.239) are overstated $99,928 Cause: There was a breakdown in the Agency’s procedures related to preparation and review of the SEFA. The Agency’s procedures for preparing the SEFA did not account for classification of certain loans subject to continuing compliance requirements. The errors of $8,641,271 related to ALN 14.239 and $4,466,122 related to ALN 14.275 were caused by the Agency not properly identifying certain loans required to be included on the SEFA. The error of $382,418 related to ALN 21.023 was caused by the Agency reducing a subscription software disbursement by the portion of the disbursement related to payments on the subscription liability. The errors of $403,795 and $99,928 related to ALN 21.026 and ALN 14.239, respectively, were caused by the Agency charging certain direct and indirect costs from fiscal year 2021, 2022, and 2023 to the programs in fiscal year 2024. Effect: The Agency adjusted its fiscal year 2024 SEFA by $13,489,811 for the errors related to ALN 14.239, 14.275, and 21.023. The expenditures for ALN 21.026 and 14.239 are overstated $403,795 and $99,928, respectively. Questioned Costs: None Context: The Agency’s expenditures of federal awards reported on the SEFA were understated by $13,489,811 which was corrected during the audit. The Agency’s expenditures of federal awards reported on the SEFA for ALN 21.026 and ALN 14.239 are overstated $403,795 and $99,928, respectively, which the Agency did not correct. Total expenditures reported on the SEFA, as adjusted for this matter, are $422,678,239. Repeat Finding?: No Recommendation: We recommend that the Agency review and strengthen its processes and controls over the preparation of the SEFA. Views of responsible officials of the auditee: We agree with the above finding and our response is included in the corrective action plan.
Item 2024-008: Allowable Costs Federal Agency: U.S. Department of Housing and Urban Development; U.S. Department of Treasury Program: COVID-19—HOME Investment Partnerships Program, American Rescue Plan (ALN 14.239); COVID-19 - Emergency Rental Assistance (ALN 21.023); COVID-19—Homeowner Assistance Fund Program (ALN 21.026) Pass-through Entity: None Federal Assistance Identification Number or Pass-Through Number: None Federal Award Year: Year ended June 30, 2024 Type of Finding: Compliance Finding and Material Weakness in Internal Control over Compliance Criteria: The Agency is required to comply with 2 CFR 200.502 which states, “The determination of when a Federal award is expended must be based on when the activity related to the Federal award occurs.” The Agency is also required to comply with 2 CFR 200.403 which indicates that allowable costs must be determined in accordance with accounting principles generally accepted in the United States of America (GAAP). Appendix VII to 2 CFR 200—State/Local Government and Indian Tribe-Wide Central Service Cost Allocation Plans 2 states, “Indirect cost rates will be reviewed, negotiated, and approved by the cognizant agency on a timely basis. Once a rate has been agreed upon, it will be accepted and used by all Federal agencies unless prohibited or limited by statute. Where a Federal awarding agency has reason to believe that special operating factors affecting its Federal awards necessitate special indirect cost rates, the funding agency will, prior to the time the rates are negotiated, notify the cognizant agency for indirect costs.” Condition: We noted the Agency charged $119,169 of direct and indirect costs from fiscal year 2021 and 2022, and direct costs from fiscal year 2023 to COVID-19—HOME Investment Partnerships Program, American Rescue Plan (ALN 14.239) in fiscal year 2024. We noted the Agency charged $426,504 of direct costs from fiscal year 2021 through 2023 to COVID-19 - Emergency Rental Assistance (ALN 21.023). We noted the Agency charged $1,153,427 of direct costs from fiscal year 2021 through 2023 to COVID-19—Homeowner Assistance Fund Program (ALN 21.026) in fiscal year 2024. These costs do not meet the allowable cost criteria as they were not determined in accordance with GAAP which requires expenses to be recorded when incurred. The Agency had an approved indirect cost rate which allowed them to charge the indirect costs in those previous fiscal years. Cause: The Agency incorrectly charged direct and indirect costs in fiscal year 2024 that were incurred in previous fiscal years for the programs noted above. Effect: The Agency inappropriately charged the above federal programs for direct and indirect costs in fiscal year 2024. During the audit, the Agency reevaluated its direct and indirect costs incurred in previous years that were charged in fiscal year 2024. The Agency identified additional direct and indirect costs incurred in fiscal year 2024 that were eligible to be charged to ALN 14.239, ALN 21.023, and ALN 21.026 which were not previously charged to the program to offset a portion of the errors identified above. This resulted in the expenditures charged to ALN 14.239, ALN 21.023, and ALN 21.026 being overstated by $99,928, $0, and $403,795, respectively. Questioned Costs: ALN 14.239 – $119,169; ALN 21.023 – $426,504; ALN 21.026 – $1,153,427; Total – $1,699,100 Context: The Agency’s expenditures of federal awards charged to ALN 14.239, ALN 21.023 and ALN 21.026 were overstated $119,169, $426,504, and $1,153,427, respectively. During the audit, the Agency identified additional direct and indirect costs incurred in fiscal year 2024 that were eligible to be charged to ALN 14.239, ALN 21.023, and ALN 21.026 which were not previously charged to the program which resulted in the expenditures charged to ALN 14.239, ALN 21.023, and ALN 21.026 being overstated by $99,928, $0, and $403,795, respectively. The total expenditures for ALN 14.239, ALN 21.023, and ALN 21.026 are $81,364,920, $41,673,294, and $14,339,711, respectively. Repeat Finding?: No Recommendation: The Agency should charge direct and indirect costs to federal programs in the year the costs are incurred and using its approved indirect cost rate. Views of responsible officials of the auditee: We agree with the above finding and our response is included in the corrective action plan.
2024-001 Internal Control over Compliance and Compliance with Reporting (Preparation of the Schedule of Expenditures of Federal Awards (SEFA)) Information on the Major Federal Programs: Department of Housing and Urban Development Federal Assistance Listing Number: 14.218 Federal Assistance Listing Name: Community Development Block Grants/Entitlement Grants Grant Number: CV-2-8 Department of Health and Human Services Federal Assistance Listing Number: 93.566 Federal Assistance Listing Name: Refugee and Entrant Assistance - State-Administered Programs Grant Number: JA-FSA-RSS-2022 Criteria: Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR part 200) Section §200.510(b) states in part: “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 CFR Section §200.502 Basis for determining Federal awards expended.” The schedule must provide total federal awards expended for each individual Federal program. In accordance with §200.302 Financial Management, a non-Federal entity's financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. The financial management system of each non-Federal entity must provide for the following: (1) Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. (3) Records that identify adequately the source and application of funds for Federally-funded activities. (4) Effective control over, and accountability for, all funds, property, and other assets.
2024-001 Internal Control over Compliance and Compliance with Reporting (Preparation of the Schedule of Expenditures of Federal Awards (SEFA)) Information on the Major Federal Programs: Department of Housing and Urban Development Federal Assistance Listing Number: 14.218 Federal Assistance Listing Name: Community Development Block Grants/Entitlement Grants Grant Number: CV-2-8 Department of Health and Human Services Federal Assistance Listing Number: 93.566 Federal Assistance Listing Name: Refugee and Entrant Assistance - State-Administered Programs Grant Number: JA-FSA-RSS-2022 Criteria: Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR part 200) Section §200.510(b) states in part: “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 CFR Section §200.502 Basis for determining Federal awards expended.” The schedule must provide total federal awards expended for each individual Federal program. In accordance with §200.302 Financial Management, a non-Federal entity's financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. The financial management system of each non-Federal entity must provide for the following: (1) Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. (3) Records that identify adequately the source and application of funds for Federally-funded activities. (4) Effective control over, and accountability for, all funds, property, and other assets.
2024-001 Internal Control over Compliance and Compliance with Reporting (Preparation of the Schedule of Expenditures of Federal Awards (SEFA)) Information on the Major Federal Programs: Department of Housing and Urban Development Federal Assistance Listing Number: 14.218 Federal Assistance Listing Name: Community Development Block Grants/Entitlement Grants Grant Number: CV-2-8 Department of Health and Human Services Federal Assistance Listing Number: 93.566 Federal Assistance Listing Name: Refugee and Entrant Assistance - State-Administered Programs Grant Number: JA-FSA-RSS-2022 Criteria: Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR part 200) Section §200.510(b) states in part: “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 CFR Section §200.502 Basis for determining Federal awards expended.” The schedule must provide total federal awards expended for each individual Federal program. In accordance with §200.302 Financial Management, a non-Federal entity's financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. The financial management system of each non-Federal entity must provide for the following: (1) Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. (3) Records that identify adequately the source and application of funds for Federally-funded activities. (4) Effective control over, and accountability for, all funds, property, and other assets.
Finding 2024-00 – Preparation of Schedule of Expenditures of Federal Awards Federal Agency: United States Department of Health and Human Services Federal Program Name: Foster Care Title IV-E Assistance Listing Number: 93.658 Pass-Through Agency: Pennsylvania Department of Human Services Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Material Weakness in Internal Control over Compliance Criteria: 2 CFR 200.510(a) states the auditee must prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements. The schedule must include the total federal awards expended as determined in accordance with 2 CFR 200.502. Additionally, the Organization receives funding from various counties across the state of Pennsylvania which consists of commingled federal, state, and local assistance with contract terms that stipulate it is the contractor’s responsibility to solicit the counties for purposes of determining the source of funding provided. Condition and Context: The expenditures included on the schedule of expenditures of federal awards (Schedule) initially prepared by the Organization included expenditures of state and local assistance. Questioned Costs: $-0- Cause: The Organization did not perform their responsibilities under the contract terms, which state it is their responsibility to solicit the counties for purposes of determining the source of funding provided during the fiscal year. Additionally, the Organization did not have adequate policies and procedures in place for accurately determining the breakdown of the commingled assistance received. Effect: The Schedule prepared by the Organization did not accurately present the federal awards expended during the fiscal year. Repeat finding: No Recommendation: We recommend the following: The Organization should establish policies and procedures to understand and ensure compliance with the Organization’s contractual obligations. The Organization should create and implement procedures to timely and accurately determine the source of funding received through various county contracts. The Organization should implement review procedures to ensure the Schedule is complete, accurate and prepared in accordance with the requirements set forth within 2 CFR 200.510. View of Responsible Officials: Management agrees with the finding and will take the necessary corrective actions.
Finding 2024-004: Schedule of Expenditures of Federal Awards (SEFA) Reporting Program: COVID-19: Coronavirus State and Local Fiscal Recovery Funds (ALN 21.027) Federal agency: U.S. Department of the Treasury Federal Award Year: Year ended June 30, 2024 Type of finding: Material weakness Criteria: 2 CFR 200.510(b) requires that “The auditee must prepare a schedule of expenditures of Federal awards (the “schedule”) for the period covered by the auditee’s financial statements, which must include the total Federal awards expended as determined in accordance with section 200.502. Condition: While performing our audit procedures, we noted that CAFB included a $5 million grant from Fairfax County on their SEFA even though CABF is considered a beneficiary related to this grant. Cause: While the Organization recognized they were considered a beneficiary, they believed it was more conservative to include the grant on their SEFA. Effect: The SEFA was overstated by $5 million. Context: An error in the amount of approximately $5 million was identified on the SEFA with total federal expenditures of approximately $46 million. Questioned costs: None Repeat finding: No Recommendation: We recommend that CAFB strengthen its controls over the preparation of the SEFA and consult directly with grantors if there are questions related to whether a grant should be included on the SEFA. Views of responsible officials: CAFB does not agree with the finding as CAFB performed its own research suggesting exclusion of the aforementioned award and included it on the SEFA after consultation with RSM. RSM Response: RSM cannot be part of CAFB’s internal control structure and suggests in the future they consult directly with grantors if there are questions related to whether a grant should be included on the SEFA.
Finding 2024-004: Schedule of Expenditures of Federal Awards (SEFA) Reporting Program: COVID-19: Coronavirus State and Local Fiscal Recovery Funds (ALN 21.027) Federal agency: U.S. Department of the Treasury Federal Award Year: Year ended June 30, 2024 Type of finding: Material weakness Criteria: 2 CFR 200.510(b) requires that “The auditee must prepare a schedule of expenditures of Federal awards (the “schedule”) for the period covered by the auditee’s financial statements, which must include the total Federal awards expended as determined in accordance with section 200.502. Condition: While performing our audit procedures, we noted that CAFB included a $5 million grant from Fairfax County on their SEFA even though CABF is considered a beneficiary related to this grant. Cause: While the Organization recognized they were considered a beneficiary, they believed it was more conservative to include the grant on their SEFA. Effect: The SEFA was overstated by $5 million. Context: An error in the amount of approximately $5 million was identified on the SEFA with total federal expenditures of approximately $46 million. Questioned costs: None Repeat finding: No Recommendation: We recommend that CAFB strengthen its controls over the preparation of the SEFA and consult directly with grantors if there are questions related to whether a grant should be included on the SEFA. Views of responsible officials: CAFB does not agree with the finding as CAFB performed its own research suggesting exclusion of the aforementioned award and included it on the SEFA after consultation with RSM. RSM Response: RSM cannot be part of CAFB’s internal control structure and suggests in the future they consult directly with grantors if there are questions related to whether a grant should be included on the SEFA.
Finding 2024-004: Schedule of Expenditures of Federal Awards (SEFA) Reporting Program: COVID-19: Coronavirus State and Local Fiscal Recovery Funds (ALN 21.027) Federal agency: U.S. Department of the Treasury Federal Award Year: Year ended June 30, 2024 Type of finding: Material weakness Criteria: 2 CFR 200.510(b) requires that “The auditee must prepare a schedule of expenditures of Federal awards (the “schedule”) for the period covered by the auditee’s financial statements, which must include the total Federal awards expended as determined in accordance with section 200.502. Condition: While performing our audit procedures, we noted that CAFB included a $5 million grant from Fairfax County on their SEFA even though CABF is considered a beneficiary related to this grant. Cause: While the Organization recognized they were considered a beneficiary, they believed it was more conservative to include the grant on their SEFA. Effect: The SEFA was overstated by $5 million. Context: An error in the amount of approximately $5 million was identified on the SEFA with total federal expenditures of approximately $46 million. Questioned costs: None Repeat finding: No Recommendation: We recommend that CAFB strengthen its controls over the preparation of the SEFA and consult directly with grantors if there are questions related to whether a grant should be included on the SEFA. Views of responsible officials: CAFB does not agree with the finding as CAFB performed its own research suggesting exclusion of the aforementioned award and included it on the SEFA after consultation with RSM. RSM Response: RSM cannot be part of CAFB’s internal control structure and suggests in the future they consult directly with grantors if there are questions related to whether a grant should be included on the SEFA.
Finding 2024-004: Schedule of Expenditures of Federal Awards (SEFA) Reporting Program: COVID-19: Coronavirus State and Local Fiscal Recovery Funds (ALN 21.027) Federal agency: U.S. Department of the Treasury Federal Award Year: Year ended June 30, 2024 Type of finding: Material weakness Criteria: 2 CFR 200.510(b) requires that “The auditee must prepare a schedule of expenditures of Federal awards (the “schedule”) for the period covered by the auditee’s financial statements, which must include the total Federal awards expended as determined in accordance with section 200.502. Condition: While performing our audit procedures, we noted that CAFB included a $5 million grant from Fairfax County on their SEFA even though CABF is considered a beneficiary related to this grant. Cause: While the Organization recognized they were considered a beneficiary, they believed it was more conservative to include the grant on their SEFA. Effect: The SEFA was overstated by $5 million. Context: An error in the amount of approximately $5 million was identified on the SEFA with total federal expenditures of approximately $46 million. Questioned costs: None Repeat finding: No Recommendation: We recommend that CAFB strengthen its controls over the preparation of the SEFA and consult directly with grantors if there are questions related to whether a grant should be included on the SEFA. Views of responsible officials: CAFB does not agree with the finding as CAFB performed its own research suggesting exclusion of the aforementioned award and included it on the SEFA after consultation with RSM. RSM Response: RSM cannot be part of CAFB’s internal control structure and suggests in the future they consult directly with grantors if there are questions related to whether a grant should be included on the SEFA.
Finding 2024-004: Schedule of Expenditures of Federal Awards (SEFA) Reporting Program: COVID-19: Coronavirus State and Local Fiscal Recovery Funds (ALN 21.027) Federal agency: U.S. Department of the Treasury Federal Award Year: Year ended June 30, 2024 Type of finding: Material weakness Criteria: 2 CFR 200.510(b) requires that “The auditee must prepare a schedule of expenditures of Federal awards (the “schedule”) for the period covered by the auditee’s financial statements, which must include the total Federal awards expended as determined in accordance with section 200.502. Condition: While performing our audit procedures, we noted that CAFB included a $5 million grant from Fairfax County on their SEFA even though CABF is considered a beneficiary related to this grant. Cause: While the Organization recognized they were considered a beneficiary, they believed it was more conservative to include the grant on their SEFA. Effect: The SEFA was overstated by $5 million. Context: An error in the amount of approximately $5 million was identified on the SEFA with total federal expenditures of approximately $46 million. Questioned costs: None Repeat finding: No Recommendation: We recommend that CAFB strengthen its controls over the preparation of the SEFA and consult directly with grantors if there are questions related to whether a grant should be included on the SEFA. Views of responsible officials: CAFB does not agree with the finding as CAFB performed its own research suggesting exclusion of the aforementioned award and included it on the SEFA after consultation with RSM. RSM Response: RSM cannot be part of CAFB’s internal control structure and suggests in the future they consult directly with grantors if there are questions related to whether a grant should be included on the SEFA.
Finding 2024-004: Schedule of Expenditures of Federal Awards (SEFA) Reporting Program: COVID-19: Coronavirus State and Local Fiscal Recovery Funds (ALN 21.027) Federal agency: U.S. Department of the Treasury Federal Award Year: Year ended June 30, 2024 Type of finding: Material weakness Criteria: 2 CFR 200.510(b) requires that “The auditee must prepare a schedule of expenditures of Federal awards (the “schedule”) for the period covered by the auditee’s financial statements, which must include the total Federal awards expended as determined in accordance with section 200.502. Condition: While performing our audit procedures, we noted that CAFB included a $5 million grant from Fairfax County on their SEFA even though CABF is considered a beneficiary related to this grant. Cause: While the Organization recognized they were considered a beneficiary, they believed it was more conservative to include the grant on their SEFA. Effect: The SEFA was overstated by $5 million. Context: An error in the amount of approximately $5 million was identified on the SEFA with total federal expenditures of approximately $46 million. Questioned costs: None Repeat finding: No Recommendation: We recommend that CAFB strengthen its controls over the preparation of the SEFA and consult directly with grantors if there are questions related to whether a grant should be included on the SEFA. Views of responsible officials: CAFB does not agree with the finding as CAFB performed its own research suggesting exclusion of the aforementioned award and included it on the SEFA after consultation with RSM. RSM Response: RSM cannot be part of CAFB’s internal control structure and suggests in the future they consult directly with grantors if there are questions related to whether a grant should be included on the SEFA.
Finding 2024-004: Schedule of Expenditures of Federal Awards (SEFA) Reporting Program: COVID-19: Coronavirus State and Local Fiscal Recovery Funds (ALN 21.027) Federal agency: U.S. Department of the Treasury Federal Award Year: Year ended June 30, 2024 Type of finding: Material weakness Criteria: 2 CFR 200.510(b) requires that “The auditee must prepare a schedule of expenditures of Federal awards (the “schedule”) for the period covered by the auditee’s financial statements, which must include the total Federal awards expended as determined in accordance with section 200.502. Condition: While performing our audit procedures, we noted that CAFB included a $5 million grant from Fairfax County on their SEFA even though CABF is considered a beneficiary related to this grant. Cause: While the Organization recognized they were considered a beneficiary, they believed it was more conservative to include the grant on their SEFA. Effect: The SEFA was overstated by $5 million. Context: An error in the amount of approximately $5 million was identified on the SEFA with total federal expenditures of approximately $46 million. Questioned costs: None Repeat finding: No Recommendation: We recommend that CAFB strengthen its controls over the preparation of the SEFA and consult directly with grantors if there are questions related to whether a grant should be included on the SEFA. Views of responsible officials: CAFB does not agree with the finding as CAFB performed its own research suggesting exclusion of the aforementioned award and included it on the SEFA after consultation with RSM. RSM Response: RSM cannot be part of CAFB’s internal control structure and suggests in the future they consult directly with grantors if there are questions related to whether a grant should be included on the SEFA.
Finding 2024-004: Schedule of Expenditures of Federal Awards (SEFA) Reporting Program: COVID-19: Coronavirus State and Local Fiscal Recovery Funds (ALN 21.027) Federal agency: U.S. Department of the Treasury Federal Award Year: Year ended June 30, 2024 Type of finding: Material weakness Criteria: 2 CFR 200.510(b) requires that “The auditee must prepare a schedule of expenditures of Federal awards (the “schedule”) for the period covered by the auditee’s financial statements, which must include the total Federal awards expended as determined in accordance with section 200.502. Condition: While performing our audit procedures, we noted that CAFB included a $5 million grant from Fairfax County on their SEFA even though CABF is considered a beneficiary related to this grant. Cause: While the Organization recognized they were considered a beneficiary, they believed it was more conservative to include the grant on their SEFA. Effect: The SEFA was overstated by $5 million. Context: An error in the amount of approximately $5 million was identified on the SEFA with total federal expenditures of approximately $46 million. Questioned costs: None Repeat finding: No Recommendation: We recommend that CAFB strengthen its controls over the preparation of the SEFA and consult directly with grantors if there are questions related to whether a grant should be included on the SEFA. Views of responsible officials: CAFB does not agree with the finding as CAFB performed its own research suggesting exclusion of the aforementioned award and included it on the SEFA after consultation with RSM. RSM Response: RSM cannot be part of CAFB’s internal control structure and suggests in the future they consult directly with grantors if there are questions related to whether a grant should be included on the SEFA.
Finding 2024-004: Schedule of Expenditures of Federal Awards (SEFA) Reporting Program: COVID-19: Coronavirus State and Local Fiscal Recovery Funds (ALN 21.027) Federal agency: U.S. Department of the Treasury Federal Award Year: Year ended June 30, 2024 Type of finding: Material weakness Criteria: 2 CFR 200.510(b) requires that “The auditee must prepare a schedule of expenditures of Federal awards (the “schedule”) for the period covered by the auditee’s financial statements, which must include the total Federal awards expended as determined in accordance with section 200.502. Condition: While performing our audit procedures, we noted that CAFB included a $5 million grant from Fairfax County on their SEFA even though CABF is considered a beneficiary related to this grant. Cause: While the Organization recognized they were considered a beneficiary, they believed it was more conservative to include the grant on their SEFA. Effect: The SEFA was overstated by $5 million. Context: An error in the amount of approximately $5 million was identified on the SEFA with total federal expenditures of approximately $46 million. Questioned costs: None Repeat finding: No Recommendation: We recommend that CAFB strengthen its controls over the preparation of the SEFA and consult directly with grantors if there are questions related to whether a grant should be included on the SEFA. Views of responsible officials: CAFB does not agree with the finding as CAFB performed its own research suggesting exclusion of the aforementioned award and included it on the SEFA after consultation with RSM. RSM Response: RSM cannot be part of CAFB’s internal control structure and suggests in the future they consult directly with grantors if there are questions related to whether a grant should be included on the SEFA.
2024-004 Preparation of and Internal controls over Schedule of Expenditures of Federal Awards Preparation (Material Weakness) Federal Agency: U.S Department of Education Pass through entity: Kansas Department of Education Program Name: Education Stabilization Fund Assistance Listing Number: 84.425 Award Period: June 30, 2024 Criteria: According to 2 CFR 200, Subpart F, the District is required to prepare a schedule of federal expenditures, which must include the total federal awards expended as determined in accordance with §200.502. An effective internal control system exists if controls are effective in preventing or detecting material misstatements in the preparation of the schedule of federal expenditures of federal awards (the schedule). It provides reasonable assurance for the reliability of financial information and compliance with laws and regulations. Condition: We have determined that there was an inadequate design of internal control over the preparation of the schedule during the fiscal year ended June 30, 2024. The current financial reporting process does not ensure accuracy and completeness in the preparation of the schedule by the District, as required by Uniform Guidance. Cause: The District’s policies and procedures were not designed to ensure the District’s preparation of the schedule in conformity with Uniform Guidance. Effect: The District did not prepare a complete and accurate schedule in conformity with Uniform Guidance as significant modifications were required. This increases the likelihood of a material misstatement and noncompliance with laws and regulations. Recommendation: We recommend the Board of Education and management review the financial reporting process. Once this review is complete, the District should then perform a risk assessment to determine the best way to implement appropriate internal controls over financial reporting to ensure that the District prepares the schedule conformity with Uniform Guidance. Questioned Costs: None. Repeat Finding: Yes. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and plans to develop proper written policies and procedures for the internal control over compliance to ensure accuracy and completeness in the District’s preparation of the schedule as required by Uniform Guidance.
Federal Agency: U.S. Department of Education Federal Program Name: Student Support and Academic Enrichment Program Assistance Listing Number: 84.424 Federal Award Identification Number and Year: 201572 (7/1/19-9/30/22) Award Period: July 1, 2019 through September 30, 2022, Liquidation Date November 30, 2022 Type of Finding: Reporting Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: 2 CFR part 200.502 and 510 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. Condition: The School System inaccurately reported expenditures of $27,779 on the schedule of expenditures of federal awards. Questioned costs: $27,779 Context: Grant award 201572 (which is tracked in Fund 7010) had a period of performance from July 1, 2019, through September 30, 2022, with a liquidation cut off period of November 30, 2022. On the Annual Financial Report (AFR) submitted to the Maryland State Department of Education (MSDE) in September 2022, the School System reported that the full award amount of $2,665,293 was expended. The School System expensed an additional $22,265 (net of adjustments) to the grant in fiscal year 2023 and an additional $27,799 in fiscal year 2024 to fulfill the $2,665,293 grant award amount. This caused a total amount of $27,779 of disbursements to be reported on the FY24 Schedule of Expenditures and Federal Awards. Cause: Accounting staff identified and processed adjustments subsequent to the period of performance and liquidation period. Effect: The Department was not compliant with the grant’s period of performance which could result in the grantor’s disallowance of the costs. Recommendation: We recommend that the School system review its procedures to ensure that amounts reported on the SEFA are in accordance with 2 CFR part 200.502 and 510. Views of responsible officials: The $27,799 was removed from the FY24 SEFA. In an ongoing effort to ensure that all grants are reported correctly and in line Grant’s Administrator will hold regular meetings (at least quarterly) with the Budget Analyst and/or Grants Accountant assigned to these grant funds. The Grants Accountant will also provide transaction and payroll detail reports to the Grants Administrator on a regular basis for review and correction when necessary.
2024-003 Internal controls over Schedule of Expenditures of Federal Awards Preparation (Material Weakness) Federal Agency: U.S Department of Education Pass through entity: Kansas Department of Education Program Name: Child Nutrition Cluster; Education Stabilization Fund Assistance Listing Numbers: 10.553, 10.555 and 10.559; 84.425 Award Period: June 30, 2024 Criteria: According to 2 CFR 200, Subpart F, the District is required to prepare a schedule of federal expenditures, which must include the total federal awards expended as determined in accordance with §200.502. An effective internal control system exists if controls are effective in preventing or detecting material misstatements in the preparation of the schedule of federal expenditures of federal awards (the schedule). It provides reasonable assurance for the reliability of financial information and compliance with laws and regulations. Condition: We have determined that there was an inadequate design of internal control over the preparation of the schedule during the fiscal year ended June 30, 2024. The current financial reporting process does not ensure accuracy and completeness in the preparation of the schedule by the District, as required by Uniform Guidance. Cause: The District’s policies and procedures were not designed to ensure the District’s preparation of the schedule in conformity with Uniform Guidance. Effect: The District did not prepare a complete and accurate schedule in conformity with Uniform Guidance as significant modifications were required. This increases the likelihood of a material misstatement and noncompliance with laws and regulations. Recommendation: We recommend the Board of Education and management review the financial reporting process. Once this review is complete, the District should then perform a risk assessment to determine the best way to implement appropriate internal controls over financial reporting to ensure that the District prepares the schedule conformity with Uniform Guidance. Questioned Costs: None. Repeat Finding: No. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and plans to develop proper written policies and procedures for the internal control over compliance to ensure accuracy and completeness in the District’s preparation of the schedule as required by Uniform Guidance.
2024-003 Internal controls over Schedule of Expenditures of Federal Awards Preparation (Material Weakness) Federal Agency: U.S Department of Education Pass through entity: Kansas Department of Education Program Name: Child Nutrition Cluster; Education Stabilization Fund Assistance Listing Numbers: 10.553, 10.555 and 10.559; 84.425 Award Period: June 30, 2024 Criteria: According to 2 CFR 200, Subpart F, the District is required to prepare a schedule of federal expenditures, which must include the total federal awards expended as determined in accordance with §200.502. An effective internal control system exists if controls are effective in preventing or detecting material misstatements in the preparation of the schedule of federal expenditures of federal awards (the schedule). It provides reasonable assurance for the reliability of financial information and compliance with laws and regulations. Condition: We have determined that there was an inadequate design of internal control over the preparation of the schedule during the fiscal year ended June 30, 2024. The current financial reporting process does not ensure accuracy and completeness in the preparation of the schedule by the District, as required by Uniform Guidance. Cause: The District’s policies and procedures were not designed to ensure the District’s preparation of the schedule in conformity with Uniform Guidance. Effect: The District did not prepare a complete and accurate schedule in conformity with Uniform Guidance as significant modifications were required. This increases the likelihood of a material misstatement and noncompliance with laws and regulations. Recommendation: We recommend the Board of Education and management review the financial reporting process. Once this review is complete, the District should then perform a risk assessment to determine the best way to implement appropriate internal controls over financial reporting to ensure that the District prepares the schedule conformity with Uniform Guidance. Questioned Costs: None. Repeat Finding: No. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and plans to develop proper written policies and procedures for the internal control over compliance to ensure accuracy and completeness in the District’s preparation of the schedule as required by Uniform Guidance.
2024-003 Internal controls over Schedule of Expenditures of Federal Awards Preparation (Material Weakness) Federal Agency: U.S Department of Education Pass through entity: Kansas Department of Education Program Name: Child Nutrition Cluster; Education Stabilization Fund Assistance Listing Numbers: 10.553, 10.555 and 10.559; 84.425 Award Period: June 30, 2024 Criteria: According to 2 CFR 200, Subpart F, the District is required to prepare a schedule of federal expenditures, which must include the total federal awards expended as determined in accordance with §200.502. An effective internal control system exists if controls are effective in preventing or detecting material misstatements in the preparation of the schedule of federal expenditures of federal awards (the schedule). It provides reasonable assurance for the reliability of financial information and compliance with laws and regulations. Condition: We have determined that there was an inadequate design of internal control over the preparation of the schedule during the fiscal year ended June 30, 2024. The current financial reporting process does not ensure accuracy and completeness in the preparation of the schedule by the District, as required by Uniform Guidance. Cause: The District’s policies and procedures were not designed to ensure the District’s preparation of the schedule in conformity with Uniform Guidance. Effect: The District did not prepare a complete and accurate schedule in conformity with Uniform Guidance as significant modifications were required. This increases the likelihood of a material misstatement and noncompliance with laws and regulations. Recommendation: We recommend the Board of Education and management review the financial reporting process. Once this review is complete, the District should then perform a risk assessment to determine the best way to implement appropriate internal controls over financial reporting to ensure that the District prepares the schedule conformity with Uniform Guidance. Questioned Costs: None. Repeat Finding: No. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and plans to develop proper written policies and procedures for the internal control over compliance to ensure accuracy and completeness in the District’s preparation of the schedule as required by Uniform Guidance.
2024-003 Internal controls over Schedule of Expenditures of Federal Awards Preparation (Material Weakness) Federal Agency: U.S Department of Education Pass through entity: Kansas Department of Education Program Name: Child Nutrition Cluster; Education Stabilization Fund Assistance Listing Numbers: 10.553, 10.555 and 10.559; 84.425 Award Period: June 30, 2024 Criteria: According to 2 CFR 200, Subpart F, the District is required to prepare a schedule of federal expenditures, which must include the total federal awards expended as determined in accordance with §200.502. An effective internal control system exists if controls are effective in preventing or detecting material misstatements in the preparation of the schedule of federal expenditures of federal awards (the schedule). It provides reasonable assurance for the reliability of financial information and compliance with laws and regulations. Condition: We have determined that there was an inadequate design of internal control over the preparation of the schedule during the fiscal year ended June 30, 2024. The current financial reporting process does not ensure accuracy and completeness in the preparation of the schedule by the District, as required by Uniform Guidance. Cause: The District’s policies and procedures were not designed to ensure the District’s preparation of the schedule in conformity with Uniform Guidance. Effect: The District did not prepare a complete and accurate schedule in conformity with Uniform Guidance as significant modifications were required. This increases the likelihood of a material misstatement and noncompliance with laws and regulations. Recommendation: We recommend the Board of Education and management review the financial reporting process. Once this review is complete, the District should then perform a risk assessment to determine the best way to implement appropriate internal controls over financial reporting to ensure that the District prepares the schedule conformity with Uniform Guidance. Questioned Costs: None. Repeat Finding: No. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and plans to develop proper written policies and procedures for the internal control over compliance to ensure accuracy and completeness in the District’s preparation of the schedule as required by Uniform Guidance.
U.S. DEPARTMENT OF EDUCATION PASSED THROUGH THE ARKANSAS DEPARTMENT OF EDUCATION COVID-19 AMERICAN RESCUE PLAN - ELEMENTARY AND SECONDARY SCHOOL EMERGENCY RELIEF FUND - AL# 84.425U PASS-THROUGH NUMBER 3105 AUDIT PERIOD - YEAR ENDED JUNE 30, 2024 Criteria or specific requirement: Office of Management and Budget (OMB) 2 CFR section 200.502 states the determination of when a Federal award is expended must be based on when the activity related to the Federal award occurs. OMB 2 CFR section 200.344(b) requires that a non-federal entity must liquidate all financial obligations incurred under the federal award no later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the federal award unless the federal awarding agency or pass-through entity authorizes an extension. American Rescue Plan - Elementary and Secondary Emergency Relief Funds must be obligated by September 30, 2024 and liquidated by January 28, 2025. Condition: The District issued two checks totaling $282,435 for the purchase of two buses on June 25, 2024 and held the checks awaiting delivery of the buses. The District reported the expenditures prior to being incurred and received federal reimbursement from the Education Stabilization Fund of $282,435. The District took possession of the buses and gave the payments to the vendor on February 5, 2025. The federal funds were not obligated or liquidated during the Education Stabilization Fund's period of performance. Cause: Lack of management oversight and adherence to program requirements. Effect or potential effect: $282,435 was reimbursed without an expenditure being incurred. Questioned costs: $282,435 Context: Identified during review of bank reconciliations in the financial statement audit. The program was not audited as a major federal program. Identification as a repeat finding: No Recommendation: The District should contact the Arkansas Division of Elementary and Secondary Education for guidance regarding this matter. Views of responsible officials: DESE has informed us that if this situation ever comes up in the future, asking for a federal extension if buses were not going to be delivered in a timely manner (by January 10, 2025). The manufacturer assured us that the buses would be delivered by November 4, 2024 so we didn’t ask for the extension. In the future, we will wait until buses are on site to write checks. We do not anticipate any ESSER ARP money to be issued in the near future.
CONDITION The audit tested quarterly Project and Expenditure reports of the State and Local Fiscal Recovery Funds (SLFRF) program for the periods ending March 2023, December 2023, and June 2024. Project and Expenditure reports are prepared and submitted by the ND Office of Management and Budget. Errors in key line items in all three quarterly Project and Expenditures Reports tested were identified. Key line items with errors included current period expenditures, cumulative expenditures, and current period obligations. Current period expenditures reported on the March 2023 and December 2023 reports did not agree to the tracking spreadsheet used to prepare the report. The net unreconciled difference in current period expenditures for these quarters was $732,036. The reason for the difference included that OMB's own SLFRF expenditures were not reported in the proper period. Cumulative expenditures reported by OMB for all three covered periods did not agree to the tracking spreadsheet used to prepare the report. The state's actual cumulative expenditures were not determined since changes or revisions can be reflected in the next Project and Expenditures report. However, cumulative expenditures reported by OMB for the covered period ending June 30, 2024, totaled $686,652,130 while cumulative expenditures reported by agencies and universities on SEFAs for the same period totaled $670,946,688. The basis of accounting used to prepare the SEFA varies amongst the agencies and universities; however, the state's cumulative expenditures are expected to reconcile to the state's SLFRF allocation in its final Project and Expenditure Report. Current period obligations reported by OMB for the covered period ending June 30, 2024, totaled $93,696,726, which should have been $0. This error did not impact the cumulative obligation amount since OMB previously reported the state's SLFRF allotment was 100% obligated in the cumulative obligation amount for the covered period ending December 31, 2023. CRITERIA According to Coronavirus State and Local Fiscal Recovery Funds Compliance and Reporting Guidance, states are required to submit quarterly Project and Expenditure Reports. The 2023 and 2024 Compliance Supplements indicate the following line items are key line items: current period obligation, cumulative obligation, current period expenditure, and cumulative expenditure are key line items. In addition, report corrections cannot be made after the reporting deadline unless prompted by Treasury staff. Any changes or revisions will need to be reflected in the next Project and Expenditure report. 2 CFR 200.502 states that the determination of when a federal award is expended must be based on when the activity related to the award occurs. In general, the activity pertains to events that require the nonfederal entity to comply with federal statutes, regulations, and the terms and conditions of federal awards. 2 CFR 200.303(a) states that non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. CAUSE OMB manages State and Local Fiscal Recovery Funds centrally and developed a process to reimburse agencies for their eligible expenditures once expenditures are incurred and agencies requested reimbursement. As a result, reimbursement from the state’s allocation of SLFRF moneys always occurs after the agency expenditure. Funds were included in the federal report for the period in which reimbursement to the agency occurred. In some cases, this resulted in the agency expenditure occurring in a period prior to the period covered under the quarterly SLFRF report. In addition, OMB's reporting process did not identify its own SLFRF expenditures in a timely manner. Lastly, OMB did not consistently utilize its tracking spreadsheet for reporting certain key line items. EFFECT State and Local Fiscal Recovery Funds (SLFRF) data reported to the U.S. Department of Treasury in quarterly Project and Expenditures Reports was inaccurate. CONTEXT In March 2021, the Federal Department of Treasury obligated funds to all 50 states under the State Local and Fiscal Recovery Fund to help states mitigate negative economic impacts caused by the COVID-19 pandemic. In November 2021, the special session of the 67th legislature obligated use of the majority of the funds to various agencies across the state. As the state was able to show that the revenue lost in years 2020 and 2021 exceeded the amount of the obligation from the Department of Treasury, the state was able to claim use of these funds under revenue replacement which allowed the state to utilize them for 'government operations' in addition to other specific uses and also allowing the state to report use of these funds under a single 'revenue replacement' project. The agencies began using the funds for purposes after they were obligated by the state legislature and began recording expenditures against the grant throughout our audit period. When these funds were initially disbursed to the state in March 2021, the funds were received by OMB and OMB then transferred reimbursement to agencies on request. The remainder of the funds were obligated by the state legislature during the 68th Legislative Assembly, which included any turnback funds obligated in previous legislation. North Dakota's project description on the reports was consistent and based on legislative appropriation. As reported, "Due to its extraordinary revenue loss during the pandemic, North Dakota’s entire SLFRF allocation is dedicated to project expenditure category group 6 – Revenue Replacement. Consequently, all expenditures will fall under project expenditure category 6.1 – Provision of Government Services. Government services, as defined by the North Dakota legislature, includes economic development and workforce development initiatives, infrastructure and deferred maintenance initiatives, state service delivery and information technology improvements, and healthcare and emergency response initiatives." Cumulative expenditures reported by OMB for the covered period ending June 30, 2024, totaled $686,652,130. Cumulative expenditures reported by agencies and universities on SEFAs for the same period totaled $670,946,688; however, the basis of accounting used to prepare the SEFA varies amongst the agencies and universities. The state's cumulative expenditures are expected to reconcile to the state's SLFRF allocation in its final Project and Expenditure Report. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Finding 2022-035 was reported in the immediate prior year. RECOMMENDATION We recommend the Office of Management and Budget ensure quarterly Project and Expenditure Reports accurately report the State's SLFRF obligations and expenditures to the Department of Treasury. OFFICE OF MANAGEMENT AND BUDGET RESPONSE The Office of Management agrees with this finding, but will continue federal reporting based on the timing of reimbursement of expenditures to other state agencies for the duration of the SLFRF reporting period. OMB will ensure all expenditures of SFLRF funding are accurately included in the reports based on the period of reimbursement. Because OMB is responsible for the state reporting under this program, it is necessary to maintain some level of control over these funds. Consequently, OMB manages the funds centrally and developed a process to reimburse agencies for their eligible expenditures once expenditures were incurred and agencies requested reimbursement. As a result, reimbursement from the state’s allocation of SLFRF moneys always occurs after the agency expenditure. Funds are included in the Federal report for the period in which reimbursement from the SLFRF occurs. In some cases, this results in the agency expenditure occurring in a period prior to the period covered under the quarterly SLFRF report in which the reimbursement is reported. To better track OMB expenditures of SLFRF moneys, which is a separate process from the reimbursement of other agencies, OMB will run specific expense reports for OMB agency expenditures to ensure all SLFRF expenses are reported in the proper period. See “Management’s Response and Corrective Action” section of this report. AUDITOR’S CONCLUDING COMMENTS While the Office of Management and Budget agrees with the finding, continuing Federal reporting based on the timing of reimbursed expenditures will likely cause further inaccurate SLFRF reporting. In addition, amounts transferred to agencies are not confirmed to not exceed incurred expenditures to ensure a reimbursement process is in place.
CONDITION The audit tested quarterly Project and Expenditure reports of the State and Local Fiscal Recovery Funds (SLFRF) program for the periods ending March 2023, December 2023, and June 2024. Project and Expenditure reports are prepared and submitted by the ND Office of Management and Budget. Errors in key line items in all three quarterly Project and Expenditures Reports tested were identified. Key line items with errors included current period expenditures, cumulative expenditures, and current period obligations. Current period expenditures reported on the March 2023 and December 2023 reports did not agree to the tracking spreadsheet used to prepare the report. The net unreconciled difference in current period expenditures for these quarters was $732,036. The reason for the difference included that OMB's own SLFRF expenditures were not reported in the proper period. Cumulative expenditures reported by OMB for all three covered periods did not agree to the tracking spreadsheet used to prepare the report. The state's actual cumulative expenditures were not determined since changes or revisions can be reflected in the next Project and Expenditures report. However, cumulative expenditures reported by OMB for the covered period ending June 30, 2024, totaled $686,652,130 while cumulative expenditures reported by agencies and universities on SEFAs for the same period totaled $670,946,688. The basis of accounting used to prepare the SEFA varies amongst the agencies and universities; however, the state's cumulative expenditures are expected to reconcile to the state's SLFRF allocation in its final Project and Expenditure Report. Current period obligations reported by OMB for the covered period ending June 30, 2024, totaled $93,696,726, which should have been $0. This error did not impact the cumulative obligation amount since OMB previously reported the state's SLFRF allotment was 100% obligated in the cumulative obligation amount for the covered period ending December 31, 2023. CRITERIA According to Coronavirus State and Local Fiscal Recovery Funds Compliance and Reporting Guidance, states are required to submit quarterly Project and Expenditure Reports. The 2023 and 2024 Compliance Supplements indicate the following line items are key line items: current period obligation, cumulative obligation, current period expenditure, and cumulative expenditure are key line items. In addition, report corrections cannot be made after the reporting deadline unless prompted by Treasury staff. Any changes or revisions will need to be reflected in the next Project and Expenditure report. 2 CFR 200.502 states that the determination of when a federal award is expended must be based on when the activity related to the award occurs. In general, the activity pertains to events that require the nonfederal entity to comply with federal statutes, regulations, and the terms and conditions of federal awards. 2 CFR 200.303(a) states that non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. CAUSE OMB manages State and Local Fiscal Recovery Funds centrally and developed a process to reimburse agencies for their eligible expenditures once expenditures are incurred and agencies requested reimbursement. As a result, reimbursement from the state’s allocation of SLFRF moneys always occurs after the agency expenditure. Funds were included in the federal report for the period in which reimbursement to the agency occurred. In some cases, this resulted in the agency expenditure occurring in a period prior to the period covered under the quarterly SLFRF report. In addition, OMB's reporting process did not identify its own SLFRF expenditures in a timely manner. Lastly, OMB did not consistently utilize its tracking spreadsheet for reporting certain key line items. EFFECT State and Local Fiscal Recovery Funds (SLFRF) data reported to the U.S. Department of Treasury in quarterly Project and Expenditures Reports was inaccurate. CONTEXT In March 2021, the Federal Department of Treasury obligated funds to all 50 states under the State Local and Fiscal Recovery Fund to help states mitigate negative economic impacts caused by the COVID-19 pandemic. In November 2021, the special session of the 67th legislature obligated use of the majority of the funds to various agencies across the state. As the state was able to show that the revenue lost in years 2020 and 2021 exceeded the amount of the obligation from the Department of Treasury, the state was able to claim use of these funds under revenue replacement which allowed the state to utilize them for 'government operations' in addition to other specific uses and also allowing the state to report use of these funds under a single 'revenue replacement' project. The agencies began using the funds for purposes after they were obligated by the state legislature and began recording expenditures against the grant throughout our audit period. When these funds were initially disbursed to the state in March 2021, the funds were received by OMB and OMB then transferred reimbursement to agencies on request. The remainder of the funds were obligated by the state legislature during the 68th Legislative Assembly, which included any turnback funds obligated in previous legislation. North Dakota's project description on the reports was consistent and based on legislative appropriation. As reported, "Due to its extraordinary revenue loss during the pandemic, North Dakota’s entire SLFRF allocation is dedicated to project expenditure category group 6 – Revenue Replacement. Consequently, all expenditures will fall under project expenditure category 6.1 – Provision of Government Services. Government services, as defined by the North Dakota legislature, includes economic development and workforce development initiatives, infrastructure and deferred maintenance initiatives, state service delivery and information technology improvements, and healthcare and emergency response initiatives." Cumulative expenditures reported by OMB for the covered period ending June 30, 2024, totaled $686,652,130. Cumulative expenditures reported by agencies and universities on SEFAs for the same period totaled $670,946,688; however, the basis of accounting used to prepare the SEFA varies amongst the agencies and universities. The state's cumulative expenditures are expected to reconcile to the state's SLFRF allocation in its final Project and Expenditure Report. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Finding 2022-035 was reported in the immediate prior year. RECOMMENDATION We recommend the Office of Management and Budget ensure quarterly Project and Expenditure Reports accurately report the State's SLFRF obligations and expenditures to the Department of Treasury. OFFICE OF MANAGEMENT AND BUDGET RESPONSE The Office of Management agrees with this finding, but will continue federal reporting based on the timing of reimbursement of expenditures to other state agencies for the duration of the SLFRF reporting period. OMB will ensure all expenditures of SFLRF funding are accurately included in the reports based on the period of reimbursement. Because OMB is responsible for the state reporting under this program, it is necessary to maintain some level of control over these funds. Consequently, OMB manages the funds centrally and developed a process to reimburse agencies for their eligible expenditures once expenditures were incurred and agencies requested reimbursement. As a result, reimbursement from the state’s allocation of SLFRF moneys always occurs after the agency expenditure. Funds are included in the Federal report for the period in which reimbursement from the SLFRF occurs. In some cases, this results in the agency expenditure occurring in a period prior to the period covered under the quarterly SLFRF report in which the reimbursement is reported. To better track OMB expenditures of SLFRF moneys, which is a separate process from the reimbursement of other agencies, OMB will run specific expense reports for OMB agency expenditures to ensure all SLFRF expenses are reported in the proper period. See “Management’s Response and Corrective Action” section of this report. AUDITOR’S CONCLUDING COMMENTS While the Office of Management and Budget agrees with the finding, continuing Federal reporting based on the timing of reimbursed expenditures will likely cause further inaccurate SLFRF reporting. In addition, amounts transferred to agencies are not confirmed to not exceed incurred expenditures to ensure a reimbursement process is in place.
CONDITION The audit tested quarterly Project and Expenditure reports of the State and Local Fiscal Recovery Funds (SLFRF) program for the periods ending March 2023, December 2023, and June 2024. Project and Expenditure reports are prepared and submitted by the ND Office of Management and Budget. Errors in key line items in all three quarterly Project and Expenditures Reports tested were identified. Key line items with errors included current period expenditures, cumulative expenditures, and current period obligations. Current period expenditures reported on the March 2023 and December 2023 reports did not agree to the tracking spreadsheet used to prepare the report. The net unreconciled difference in current period expenditures for these quarters was $732,036. The reason for the difference included that OMB's own SLFRF expenditures were not reported in the proper period. Cumulative expenditures reported by OMB for all three covered periods did not agree to the tracking spreadsheet used to prepare the report. The state's actual cumulative expenditures were not determined since changes or revisions can be reflected in the next Project and Expenditures report. However, cumulative expenditures reported by OMB for the covered period ending June 30, 2024, totaled $686,652,130 while cumulative expenditures reported by agencies and universities on SEFAs for the same period totaled $670,946,688. The basis of accounting used to prepare the SEFA varies amongst the agencies and universities; however, the state's cumulative expenditures are expected to reconcile to the state's SLFRF allocation in its final Project and Expenditure Report. Current period obligations reported by OMB for the covered period ending June 30, 2024, totaled $93,696,726, which should have been $0. This error did not impact the cumulative obligation amount since OMB previously reported the state's SLFRF allotment was 100% obligated in the cumulative obligation amount for the covered period ending December 31, 2023. CRITERIA According to Coronavirus State and Local Fiscal Recovery Funds Compliance and Reporting Guidance, states are required to submit quarterly Project and Expenditure Reports. The 2023 and 2024 Compliance Supplements indicate the following line items are key line items: current period obligation, cumulative obligation, current period expenditure, and cumulative expenditure are key line items. In addition, report corrections cannot be made after the reporting deadline unless prompted by Treasury staff. Any changes or revisions will need to be reflected in the next Project and Expenditure report. 2 CFR 200.502 states that the determination of when a federal award is expended must be based on when the activity related to the award occurs. In general, the activity pertains to events that require the nonfederal entity to comply with federal statutes, regulations, and the terms and conditions of federal awards. 2 CFR 200.303(a) states that non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. CAUSE OMB manages State and Local Fiscal Recovery Funds centrally and developed a process to reimburse agencies for their eligible expenditures once expenditures are incurred and agencies requested reimbursement. As a result, reimbursement from the state’s allocation of SLFRF moneys always occurs after the agency expenditure. Funds were included in the federal report for the period in which reimbursement to the agency occurred. In some cases, this resulted in the agency expenditure occurring in a period prior to the period covered under the quarterly SLFRF report. In addition, OMB's reporting process did not identify its own SLFRF expenditures in a timely manner. Lastly, OMB did not consistently utilize its tracking spreadsheet for reporting certain key line items. EFFECT State and Local Fiscal Recovery Funds (SLFRF) data reported to the U.S. Department of Treasury in quarterly Project and Expenditures Reports was inaccurate. CONTEXT In March 2021, the Federal Department of Treasury obligated funds to all 50 states under the State Local and Fiscal Recovery Fund to help states mitigate negative economic impacts caused by the COVID-19 pandemic. In November 2021, the special session of the 67th legislature obligated use of the majority of the funds to various agencies across the state. As the state was able to show that the revenue lost in years 2020 and 2021 exceeded the amount of the obligation from the Department of Treasury, the state was able to claim use of these funds under revenue replacement which allowed the state to utilize them for 'government operations' in addition to other specific uses and also allowing the state to report use of these funds under a single 'revenue replacement' project. The agencies began using the funds for purposes after they were obligated by the state legislature and began recording expenditures against the grant throughout our audit period. When these funds were initially disbursed to the state in March 2021, the funds were received by OMB and OMB then transferred reimbursement to agencies on request. The remainder of the funds were obligated by the state legislature during the 68th Legislative Assembly, which included any turnback funds obligated in previous legislation. North Dakota's project description on the reports was consistent and based on legislative appropriation. As reported, "Due to its extraordinary revenue loss during the pandemic, North Dakota’s entire SLFRF allocation is dedicated to project expenditure category group 6 – Revenue Replacement. Consequently, all expenditures will fall under project expenditure category 6.1 – Provision of Government Services. Government services, as defined by the North Dakota legislature, includes economic development and workforce development initiatives, infrastructure and deferred maintenance initiatives, state service delivery and information technology improvements, and healthcare and emergency response initiatives." Cumulative expenditures reported by OMB for the covered period ending June 30, 2024, totaled $686,652,130. Cumulative expenditures reported by agencies and universities on SEFAs for the same period totaled $670,946,688; however, the basis of accounting used to prepare the SEFA varies amongst the agencies and universities. The state's cumulative expenditures are expected to reconcile to the state's SLFRF allocation in its final Project and Expenditure Report. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Finding 2022-035 was reported in the immediate prior year. RECOMMENDATION We recommend the Office of Management and Budget ensure quarterly Project and Expenditure Reports accurately report the State's SLFRF obligations and expenditures to the Department of Treasury. OFFICE OF MANAGEMENT AND BUDGET RESPONSE The Office of Management agrees with this finding, but will continue federal reporting based on the timing of reimbursement of expenditures to other state agencies for the duration of the SLFRF reporting period. OMB will ensure all expenditures of SFLRF funding are accurately included in the reports based on the period of reimbursement. Because OMB is responsible for the state reporting under this program, it is necessary to maintain some level of control over these funds. Consequently, OMB manages the funds centrally and developed a process to reimburse agencies for their eligible expenditures once expenditures were incurred and agencies requested reimbursement. As a result, reimbursement from the state’s allocation of SLFRF moneys always occurs after the agency expenditure. Funds are included in the Federal report for the period in which reimbursement from the SLFRF occurs. In some cases, this results in the agency expenditure occurring in a period prior to the period covered under the quarterly SLFRF report in which the reimbursement is reported. To better track OMB expenditures of SLFRF moneys, which is a separate process from the reimbursement of other agencies, OMB will run specific expense reports for OMB agency expenditures to ensure all SLFRF expenses are reported in the proper period. See “Management’s Response and Corrective Action” section of this report. AUDITOR’S CONCLUDING COMMENTS While the Office of Management and Budget agrees with the finding, continuing Federal reporting based on the timing of reimbursed expenditures will likely cause further inaccurate SLFRF reporting. In addition, amounts transferred to agencies are not confirmed to not exceed incurred expenditures to ensure a reimbursement process is in place.
CONDITION The audit tested quarterly Project and Expenditure reports of the State and Local Fiscal Recovery Funds (SLFRF) program for the periods ending March 2023, December 2023, and June 2024. Project and Expenditure reports are prepared and submitted by the ND Office of Management and Budget. Errors in key line items in all three quarterly Project and Expenditures Reports tested were identified. Key line items with errors included current period expenditures, cumulative expenditures, and current period obligations. Current period expenditures reported on the March 2023 and December 2023 reports did not agree to the tracking spreadsheet used to prepare the report. The net unreconciled difference in current period expenditures for these quarters was $732,036. The reason for the difference included that OMB's own SLFRF expenditures were not reported in the proper period. Cumulative expenditures reported by OMB for all three covered periods did not agree to the tracking spreadsheet used to prepare the report. The state's actual cumulative expenditures were not determined since changes or revisions can be reflected in the next Project and Expenditures report. However, cumulative expenditures reported by OMB for the covered period ending June 30, 2024, totaled $686,652,130 while cumulative expenditures reported by agencies and universities on SEFAs for the same period totaled $670,946,688. The basis of accounting used to prepare the SEFA varies amongst the agencies and universities; however, the state's cumulative expenditures are expected to reconcile to the state's SLFRF allocation in its final Project and Expenditure Report. Current period obligations reported by OMB for the covered period ending June 30, 2024, totaled $93,696,726, which should have been $0. This error did not impact the cumulative obligation amount since OMB previously reported the state's SLFRF allotment was 100% obligated in the cumulative obligation amount for the covered period ending December 31, 2023. CRITERIA According to Coronavirus State and Local Fiscal Recovery Funds Compliance and Reporting Guidance, states are required to submit quarterly Project and Expenditure Reports. The 2023 and 2024 Compliance Supplements indicate the following line items are key line items: current period obligation, cumulative obligation, current period expenditure, and cumulative expenditure are key line items. In addition, report corrections cannot be made after the reporting deadline unless prompted by Treasury staff. Any changes or revisions will need to be reflected in the next Project and Expenditure report. 2 CFR 200.502 states that the determination of when a federal award is expended must be based on when the activity related to the award occurs. In general, the activity pertains to events that require the nonfederal entity to comply with federal statutes, regulations, and the terms and conditions of federal awards. 2 CFR 200.303(a) states that non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. CAUSE OMB manages State and Local Fiscal Recovery Funds centrally and developed a process to reimburse agencies for their eligible expenditures once expenditures are incurred and agencies requested reimbursement. As a result, reimbursement from the state’s allocation of SLFRF moneys always occurs after the agency expenditure. Funds were included in the federal report for the period in which reimbursement to the agency occurred. In some cases, this resulted in the agency expenditure occurring in a period prior to the period covered under the quarterly SLFRF report. In addition, OMB's reporting process did not identify its own SLFRF expenditures in a timely manner. Lastly, OMB did not consistently utilize its tracking spreadsheet for reporting certain key line items. EFFECT State and Local Fiscal Recovery Funds (SLFRF) data reported to the U.S. Department of Treasury in quarterly Project and Expenditures Reports was inaccurate. CONTEXT In March 2021, the Federal Department of Treasury obligated funds to all 50 states under the State Local and Fiscal Recovery Fund to help states mitigate negative economic impacts caused by the COVID-19 pandemic. In November 2021, the special session of the 67th legislature obligated use of the majority of the funds to various agencies across the state. As the state was able to show that the revenue lost in years 2020 and 2021 exceeded the amount of the obligation from the Department of Treasury, the state was able to claim use of these funds under revenue replacement which allowed the state to utilize them for 'government operations' in addition to other specific uses and also allowing the state to report use of these funds under a single 'revenue replacement' project. The agencies began using the funds for purposes after they were obligated by the state legislature and began recording expenditures against the grant throughout our audit period. When these funds were initially disbursed to the state in March 2021, the funds were received by OMB and OMB then transferred reimbursement to agencies on request. The remainder of the funds were obligated by the state legislature during the 68th Legislative Assembly, which included any turnback funds obligated in previous legislation. North Dakota's project description on the reports was consistent and based on legislative appropriation. As reported, "Due to its extraordinary revenue loss during the pandemic, North Dakota’s entire SLFRF allocation is dedicated to project expenditure category group 6 – Revenue Replacement. Consequently, all expenditures will fall under project expenditure category 6.1 – Provision of Government Services. Government services, as defined by the North Dakota legislature, includes economic development and workforce development initiatives, infrastructure and deferred maintenance initiatives, state service delivery and information technology improvements, and healthcare and emergency response initiatives." Cumulative expenditures reported by OMB for the covered period ending June 30, 2024, totaled $686,652,130. Cumulative expenditures reported by agencies and universities on SEFAs for the same period totaled $670,946,688; however, the basis of accounting used to prepare the SEFA varies amongst the agencies and universities. The state's cumulative expenditures are expected to reconcile to the state's SLFRF allocation in its final Project and Expenditure Report. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Finding 2022-035 was reported in the immediate prior year. RECOMMENDATION We recommend the Office of Management and Budget ensure quarterly Project and Expenditure Reports accurately report the State's SLFRF obligations and expenditures to the Department of Treasury. OFFICE OF MANAGEMENT AND BUDGET RESPONSE The Office of Management agrees with this finding, but will continue federal reporting based on the timing of reimbursement of expenditures to other state agencies for the duration of the SLFRF reporting period. OMB will ensure all expenditures of SFLRF funding are accurately included in the reports based on the period of reimbursement. Because OMB is responsible for the state reporting under this program, it is necessary to maintain some level of control over these funds. Consequently, OMB manages the funds centrally and developed a process to reimburse agencies for their eligible expenditures once expenditures were incurred and agencies requested reimbursement. As a result, reimbursement from the state’s allocation of SLFRF moneys always occurs after the agency expenditure. Funds are included in the Federal report for the period in which reimbursement from the SLFRF occurs. In some cases, this results in the agency expenditure occurring in a period prior to the period covered under the quarterly SLFRF report in which the reimbursement is reported. To better track OMB expenditures of SLFRF moneys, which is a separate process from the reimbursement of other agencies, OMB will run specific expense reports for OMB agency expenditures to ensure all SLFRF expenses are reported in the proper period. See “Management’s Response and Corrective Action” section of this report. AUDITOR’S CONCLUDING COMMENTS While the Office of Management and Budget agrees with the finding, continuing Federal reporting based on the timing of reimbursed expenditures will likely cause further inaccurate SLFRF reporting. In addition, amounts transferred to agencies are not confirmed to not exceed incurred expenditures to ensure a reimbursement process is in place.
CONDITION The audit tested quarterly Project and Expenditure reports of the State and Local Fiscal Recovery Funds (SLFRF) program for the periods ending March 2023, December 2023, and June 2024. Project and Expenditure reports are prepared and submitted by the ND Office of Management and Budget. Errors in key line items in all three quarterly Project and Expenditures Reports tested were identified. Key line items with errors included current period expenditures, cumulative expenditures, and current period obligations. Current period expenditures reported on the March 2023 and December 2023 reports did not agree to the tracking spreadsheet used to prepare the report. The net unreconciled difference in current period expenditures for these quarters was $732,036. The reason for the difference included that OMB's own SLFRF expenditures were not reported in the proper period. Cumulative expenditures reported by OMB for all three covered periods did not agree to the tracking spreadsheet used to prepare the report. The state's actual cumulative expenditures were not determined since changes or revisions can be reflected in the next Project and Expenditures report. However, cumulative expenditures reported by OMB for the covered period ending June 30, 2024, totaled $686,652,130 while cumulative expenditures reported by agencies and universities on SEFAs for the same period totaled $670,946,688. The basis of accounting used to prepare the SEFA varies amongst the agencies and universities; however, the state's cumulative expenditures are expected to reconcile to the state's SLFRF allocation in its final Project and Expenditure Report. Current period obligations reported by OMB for the covered period ending June 30, 2024, totaled $93,696,726, which should have been $0. This error did not impact the cumulative obligation amount since OMB previously reported the state's SLFRF allotment was 100% obligated in the cumulative obligation amount for the covered period ending December 31, 2023. CRITERIA According to Coronavirus State and Local Fiscal Recovery Funds Compliance and Reporting Guidance, states are required to submit quarterly Project and Expenditure Reports. The 2023 and 2024 Compliance Supplements indicate the following line items are key line items: current period obligation, cumulative obligation, current period expenditure, and cumulative expenditure are key line items. In addition, report corrections cannot be made after the reporting deadline unless prompted by Treasury staff. Any changes or revisions will need to be reflected in the next Project and Expenditure report. 2 CFR 200.502 states that the determination of when a federal award is expended must be based on when the activity related to the award occurs. In general, the activity pertains to events that require the nonfederal entity to comply with federal statutes, regulations, and the terms and conditions of federal awards. 2 CFR 200.303(a) states that non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. CAUSE OMB manages State and Local Fiscal Recovery Funds centrally and developed a process to reimburse agencies for their eligible expenditures once expenditures are incurred and agencies requested reimbursement. As a result, reimbursement from the state’s allocation of SLFRF moneys always occurs after the agency expenditure. Funds were included in the federal report for the period in which reimbursement to the agency occurred. In some cases, this resulted in the agency expenditure occurring in a period prior to the period covered under the quarterly SLFRF report. In addition, OMB's reporting process did not identify its own SLFRF expenditures in a timely manner. Lastly, OMB did not consistently utilize its tracking spreadsheet for reporting certain key line items. EFFECT State and Local Fiscal Recovery Funds (SLFRF) data reported to the U.S. Department of Treasury in quarterly Project and Expenditures Reports was inaccurate. CONTEXT In March 2021, the Federal Department of Treasury obligated funds to all 50 states under the State Local and Fiscal Recovery Fund to help states mitigate negative economic impacts caused by the COVID-19 pandemic. In November 2021, the special session of the 67th legislature obligated use of the majority of the funds to various agencies across the state. As the state was able to show that the revenue lost in years 2020 and 2021 exceeded the amount of the obligation from the Department of Treasury, the state was able to claim use of these funds under revenue replacement which allowed the state to utilize them for 'government operations' in addition to other specific uses and also allowing the state to report use of these funds under a single 'revenue replacement' project. The agencies began using the funds for purposes after they were obligated by the state legislature and began recording expenditures against the grant throughout our audit period. When these funds were initially disbursed to the state in March 2021, the funds were received by OMB and OMB then transferred reimbursement to agencies on request. The remainder of the funds were obligated by the state legislature during the 68th Legislative Assembly, which included any turnback funds obligated in previous legislation. North Dakota's project description on the reports was consistent and based on legislative appropriation. As reported, "Due to its extraordinary revenue loss during the pandemic, North Dakota’s entire SLFRF allocation is dedicated to project expenditure category group 6 – Revenue Replacement. Consequently, all expenditures will fall under project expenditure category 6.1 – Provision of Government Services. Government services, as defined by the North Dakota legislature, includes economic development and workforce development initiatives, infrastructure and deferred maintenance initiatives, state service delivery and information technology improvements, and healthcare and emergency response initiatives." Cumulative expenditures reported by OMB for the covered period ending June 30, 2024, totaled $686,652,130. Cumulative expenditures reported by agencies and universities on SEFAs for the same period totaled $670,946,688; however, the basis of accounting used to prepare the SEFA varies amongst the agencies and universities. The state's cumulative expenditures are expected to reconcile to the state's SLFRF allocation in its final Project and Expenditure Report. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Finding 2022-035 was reported in the immediate prior year. RECOMMENDATION We recommend the Office of Management and Budget ensure quarterly Project and Expenditure Reports accurately report the State's SLFRF obligations and expenditures to the Department of Treasury. OFFICE OF MANAGEMENT AND BUDGET RESPONSE The Office of Management agrees with this finding, but will continue federal reporting based on the timing of reimbursement of expenditures to other state agencies for the duration of the SLFRF reporting period. OMB will ensure all expenditures of SFLRF funding are accurately included in the reports based on the period of reimbursement. Because OMB is responsible for the state reporting under this program, it is necessary to maintain some level of control over these funds. Consequently, OMB manages the funds centrally and developed a process to reimburse agencies for their eligible expenditures once expenditures were incurred and agencies requested reimbursement. As a result, reimbursement from the state’s allocation of SLFRF moneys always occurs after the agency expenditure. Funds are included in the Federal report for the period in which reimbursement from the SLFRF occurs. In some cases, this results in the agency expenditure occurring in a period prior to the period covered under the quarterly SLFRF report in which the reimbursement is reported. To better track OMB expenditures of SLFRF moneys, which is a separate process from the reimbursement of other agencies, OMB will run specific expense reports for OMB agency expenditures to ensure all SLFRF expenses are reported in the proper period. See “Management’s Response and Corrective Action” section of this report. AUDITOR’S CONCLUDING COMMENTS While the Office of Management and Budget agrees with the finding, continuing Federal reporting based on the timing of reimbursed expenditures will likely cause further inaccurate SLFRF reporting. In addition, amounts transferred to agencies are not confirmed to not exceed incurred expenditures to ensure a reimbursement process is in place.
CONDITION The audit tested quarterly Project and Expenditure reports of the State and Local Fiscal Recovery Funds (SLFRF) program for the periods ending March 2023, December 2023, and June 2024. Project and Expenditure reports are prepared and submitted by the ND Office of Management and Budget. Errors in key line items in all three quarterly Project and Expenditures Reports tested were identified. Key line items with errors included current period expenditures, cumulative expenditures, and current period obligations. Current period expenditures reported on the March 2023 and December 2023 reports did not agree to the tracking spreadsheet used to prepare the report. The net unreconciled difference in current period expenditures for these quarters was $732,036. The reason for the difference included that OMB's own SLFRF expenditures were not reported in the proper period. Cumulative expenditures reported by OMB for all three covered periods did not agree to the tracking spreadsheet used to prepare the report. The state's actual cumulative expenditures were not determined since changes or revisions can be reflected in the next Project and Expenditures report. However, cumulative expenditures reported by OMB for the covered period ending June 30, 2024, totaled $686,652,130 while cumulative expenditures reported by agencies and universities on SEFAs for the same period totaled $670,946,688. The basis of accounting used to prepare the SEFA varies amongst the agencies and universities; however, the state's cumulative expenditures are expected to reconcile to the state's SLFRF allocation in its final Project and Expenditure Report. Current period obligations reported by OMB for the covered period ending June 30, 2024, totaled $93,696,726, which should have been $0. This error did not impact the cumulative obligation amount since OMB previously reported the state's SLFRF allotment was 100% obligated in the cumulative obligation amount for the covered period ending December 31, 2023. CRITERIA According to Coronavirus State and Local Fiscal Recovery Funds Compliance and Reporting Guidance, states are required to submit quarterly Project and Expenditure Reports. The 2023 and 2024 Compliance Supplements indicate the following line items are key line items: current period obligation, cumulative obligation, current period expenditure, and cumulative expenditure are key line items. In addition, report corrections cannot be made after the reporting deadline unless prompted by Treasury staff. Any changes or revisions will need to be reflected in the next Project and Expenditure report. 2 CFR 200.502 states that the determination of when a federal award is expended must be based on when the activity related to the award occurs. In general, the activity pertains to events that require the nonfederal entity to comply with federal statutes, regulations, and the terms and conditions of federal awards. 2 CFR 200.303(a) states that non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. CAUSE OMB manages State and Local Fiscal Recovery Funds centrally and developed a process to reimburse agencies for their eligible expenditures once expenditures are incurred and agencies requested reimbursement. As a result, reimbursement from the state’s allocation of SLFRF moneys always occurs after the agency expenditure. Funds were included in the federal report for the period in which reimbursement to the agency occurred. In some cases, this resulted in the agency expenditure occurring in a period prior to the period covered under the quarterly SLFRF report. In addition, OMB's reporting process did not identify its own SLFRF expenditures in a timely manner. Lastly, OMB did not consistently utilize its tracking spreadsheet for reporting certain key line items. EFFECT State and Local Fiscal Recovery Funds (SLFRF) data reported to the U.S. Department of Treasury in quarterly Project and Expenditures Reports was inaccurate. CONTEXT In March 2021, the Federal Department of Treasury obligated funds to all 50 states under the State Local and Fiscal Recovery Fund to help states mitigate negative economic impacts caused by the COVID-19 pandemic. In November 2021, the special session of the 67th legislature obligated use of the majority of the funds to various agencies across the state. As the state was able to show that the revenue lost in years 2020 and 2021 exceeded the amount of the obligation from the Department of Treasury, the state was able to claim use of these funds under revenue replacement which allowed the state to utilize them for 'government operations' in addition to other specific uses and also allowing the state to report use of these funds under a single 'revenue replacement' project. The agencies began using the funds for purposes after they were obligated by the state legislature and began recording expenditures against the grant throughout our audit period. When these funds were initially disbursed to the state in March 2021, the funds were received by OMB and OMB then transferred reimbursement to agencies on request. The remainder of the funds were obligated by the state legislature during the 68th Legislative Assembly, which included any turnback funds obligated in previous legislation. North Dakota's project description on the reports was consistent and based on legislative appropriation. As reported, "Due to its extraordinary revenue loss during the pandemic, North Dakota’s entire SLFRF allocation is dedicated to project expenditure category group 6 – Revenue Replacement. Consequently, all expenditures will fall under project expenditure category 6.1 – Provision of Government Services. Government services, as defined by the North Dakota legislature, includes economic development and workforce development initiatives, infrastructure and deferred maintenance initiatives, state service delivery and information technology improvements, and healthcare and emergency response initiatives." Cumulative expenditures reported by OMB for the covered period ending June 30, 2024, totaled $686,652,130. Cumulative expenditures reported by agencies and universities on SEFAs for the same period totaled $670,946,688; however, the basis of accounting used to prepare the SEFA varies amongst the agencies and universities. The state's cumulative expenditures are expected to reconcile to the state's SLFRF allocation in its final Project and Expenditure Report. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Finding 2022-035 was reported in the immediate prior year. RECOMMENDATION We recommend the Office of Management and Budget ensure quarterly Project and Expenditure Reports accurately report the State's SLFRF obligations and expenditures to the Department of Treasury. OFFICE OF MANAGEMENT AND BUDGET RESPONSE The Office of Management agrees with this finding, but will continue federal reporting based on the timing of reimbursement of expenditures to other state agencies for the duration of the SLFRF reporting period. OMB will ensure all expenditures of SFLRF funding are accurately included in the reports based on the period of reimbursement. Because OMB is responsible for the state reporting under this program, it is necessary to maintain some level of control over these funds. Consequently, OMB manages the funds centrally and developed a process to reimburse agencies for their eligible expenditures once expenditures were incurred and agencies requested reimbursement. As a result, reimbursement from the state’s allocation of SLFRF moneys always occurs after the agency expenditure. Funds are included in the Federal report for the period in which reimbursement from the SLFRF occurs. In some cases, this results in the agency expenditure occurring in a period prior to the period covered under the quarterly SLFRF report in which the reimbursement is reported. To better track OMB expenditures of SLFRF moneys, which is a separate process from the reimbursement of other agencies, OMB will run specific expense reports for OMB agency expenditures to ensure all SLFRF expenses are reported in the proper period. See “Management’s Response and Corrective Action” section of this report. AUDITOR’S CONCLUDING COMMENTS While the Office of Management and Budget agrees with the finding, continuing Federal reporting based on the timing of reimbursed expenditures will likely cause further inaccurate SLFRF reporting. In addition, amounts transferred to agencies are not confirmed to not exceed incurred expenditures to ensure a reimbursement process is in place.
CONDITION The audit tested quarterly Project and Expenditure reports of the State and Local Fiscal Recovery Funds (SLFRF) program for the periods ending March 2023, December 2023, and June 2024. Project and Expenditure reports are prepared and submitted by the ND Office of Management and Budget. Errors in key line items in all three quarterly Project and Expenditures Reports tested were identified. Key line items with errors included current period expenditures, cumulative expenditures, and current period obligations. Current period expenditures reported on the March 2023 and December 2023 reports did not agree to the tracking spreadsheet used to prepare the report. The net unreconciled difference in current period expenditures for these quarters was $732,036. The reason for the difference included that OMB's own SLFRF expenditures were not reported in the proper period. Cumulative expenditures reported by OMB for all three covered periods did not agree to the tracking spreadsheet used to prepare the report. The state's actual cumulative expenditures were not determined since changes or revisions can be reflected in the next Project and Expenditures report. However, cumulative expenditures reported by OMB for the covered period ending June 30, 2024, totaled $686,652,130 while cumulative expenditures reported by agencies and universities on SEFAs for the same period totaled $670,946,688. The basis of accounting used to prepare the SEFA varies amongst the agencies and universities; however, the state's cumulative expenditures are expected to reconcile to the state's SLFRF allocation in its final Project and Expenditure Report. Current period obligations reported by OMB for the covered period ending June 30, 2024, totaled $93,696,726, which should have been $0. This error did not impact the cumulative obligation amount since OMB previously reported the state's SLFRF allotment was 100% obligated in the cumulative obligation amount for the covered period ending December 31, 2023. CRITERIA According to Coronavirus State and Local Fiscal Recovery Funds Compliance and Reporting Guidance, states are required to submit quarterly Project and Expenditure Reports. The 2023 and 2024 Compliance Supplements indicate the following line items are key line items: current period obligation, cumulative obligation, current period expenditure, and cumulative expenditure are key line items. In addition, report corrections cannot be made after the reporting deadline unless prompted by Treasury staff. Any changes or revisions will need to be reflected in the next Project and Expenditure report. 2 CFR 200.502 states that the determination of when a federal award is expended must be based on when the activity related to the award occurs. In general, the activity pertains to events that require the nonfederal entity to comply with federal statutes, regulations, and the terms and conditions of federal awards. 2 CFR 200.303(a) states that non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. CAUSE OMB manages State and Local Fiscal Recovery Funds centrally and developed a process to reimburse agencies for their eligible expenditures once expenditures are incurred and agencies requested reimbursement. As a result, reimbursement from the state’s allocation of SLFRF moneys always occurs after the agency expenditure. Funds were included in the federal report for the period in which reimbursement to the agency occurred. In some cases, this resulted in the agency expenditure occurring in a period prior to the period covered under the quarterly SLFRF report. In addition, OMB's reporting process did not identify its own SLFRF expenditures in a timely manner. Lastly, OMB did not consistently utilize its tracking spreadsheet for reporting certain key line items. EFFECT State and Local Fiscal Recovery Funds (SLFRF) data reported to the U.S. Department of Treasury in quarterly Project and Expenditures Reports was inaccurate. CONTEXT In March 2021, the Federal Department of Treasury obligated funds to all 50 states under the State Local and Fiscal Recovery Fund to help states mitigate negative economic impacts caused by the COVID-19 pandemic. In November 2021, the special session of the 67th legislature obligated use of the majority of the funds to various agencies across the state. As the state was able to show that the revenue lost in years 2020 and 2021 exceeded the amount of the obligation from the Department of Treasury, the state was able to claim use of these funds under revenue replacement which allowed the state to utilize them for 'government operations' in addition to other specific uses and also allowing the state to report use of these funds under a single 'revenue replacement' project. The agencies began using the funds for purposes after they were obligated by the state legislature and began recording expenditures against the grant throughout our audit period. When these funds were initially disbursed to the state in March 2021, the funds were received by OMB and OMB then transferred reimbursement to agencies on request. The remainder of the funds were obligated by the state legislature during the 68th Legislative Assembly, which included any turnback funds obligated in previous legislation. North Dakota's project description on the reports was consistent and based on legislative appropriation. As reported, "Due to its extraordinary revenue loss during the pandemic, North Dakota’s entire SLFRF allocation is dedicated to project expenditure category group 6 – Revenue Replacement. Consequently, all expenditures will fall under project expenditure category 6.1 – Provision of Government Services. Government services, as defined by the North Dakota legislature, includes economic development and workforce development initiatives, infrastructure and deferred maintenance initiatives, state service delivery and information technology improvements, and healthcare and emergency response initiatives." Cumulative expenditures reported by OMB for the covered period ending June 30, 2024, totaled $686,652,130. Cumulative expenditures reported by agencies and universities on SEFAs for the same period totaled $670,946,688; however, the basis of accounting used to prepare the SEFA varies amongst the agencies and universities. The state's cumulative expenditures are expected to reconcile to the state's SLFRF allocation in its final Project and Expenditure Report. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Finding 2022-035 was reported in the immediate prior year. RECOMMENDATION We recommend the Office of Management and Budget ensure quarterly Project and Expenditure Reports accurately report the State's SLFRF obligations and expenditures to the Department of Treasury. OFFICE OF MANAGEMENT AND BUDGET RESPONSE The Office of Management agrees with this finding, but will continue federal reporting based on the timing of reimbursement of expenditures to other state agencies for the duration of the SLFRF reporting period. OMB will ensure all expenditures of SFLRF funding are accurately included in the reports based on the period of reimbursement. Because OMB is responsible for the state reporting under this program, it is necessary to maintain some level of control over these funds. Consequently, OMB manages the funds centrally and developed a process to reimburse agencies for their eligible expenditures once expenditures were incurred and agencies requested reimbursement. As a result, reimbursement from the state’s allocation of SLFRF moneys always occurs after the agency expenditure. Funds are included in the Federal report for the period in which reimbursement from the SLFRF occurs. In some cases, this results in the agency expenditure occurring in a period prior to the period covered under the quarterly SLFRF report in which the reimbursement is reported. To better track OMB expenditures of SLFRF moneys, which is a separate process from the reimbursement of other agencies, OMB will run specific expense reports for OMB agency expenditures to ensure all SLFRF expenses are reported in the proper period. See “Management’s Response and Corrective Action” section of this report. AUDITOR’S CONCLUDING COMMENTS While the Office of Management and Budget agrees with the finding, continuing Federal reporting based on the timing of reimbursed expenditures will likely cause further inaccurate SLFRF reporting. In addition, amounts transferred to agencies are not confirmed to not exceed incurred expenditures to ensure a reimbursement process is in place.
CONDITION The audit tested quarterly Project and Expenditure reports of the State and Local Fiscal Recovery Funds (SLFRF) program for the periods ending March 2023, December 2023, and June 2024. Project and Expenditure reports are prepared and submitted by the ND Office of Management and Budget. Errors in key line items in all three quarterly Project and Expenditures Reports tested were identified. Key line items with errors included current period expenditures, cumulative expenditures, and current period obligations. Current period expenditures reported on the March 2023 and December 2023 reports did not agree to the tracking spreadsheet used to prepare the report. The net unreconciled difference in current period expenditures for these quarters was $732,036. The reason for the difference included that OMB's own SLFRF expenditures were not reported in the proper period. Cumulative expenditures reported by OMB for all three covered periods did not agree to the tracking spreadsheet used to prepare the report. The state's actual cumulative expenditures were not determined since changes or revisions can be reflected in the next Project and Expenditures report. However, cumulative expenditures reported by OMB for the covered period ending June 30, 2024, totaled $686,652,130 while cumulative expenditures reported by agencies and universities on SEFAs for the same period totaled $670,946,688. The basis of accounting used to prepare the SEFA varies amongst the agencies and universities; however, the state's cumulative expenditures are expected to reconcile to the state's SLFRF allocation in its final Project and Expenditure Report. Current period obligations reported by OMB for the covered period ending June 30, 2024, totaled $93,696,726, which should have been $0. This error did not impact the cumulative obligation amount since OMB previously reported the state's SLFRF allotment was 100% obligated in the cumulative obligation amount for the covered period ending December 31, 2023. CRITERIA According to Coronavirus State and Local Fiscal Recovery Funds Compliance and Reporting Guidance, states are required to submit quarterly Project and Expenditure Reports. The 2023 and 2024 Compliance Supplements indicate the following line items are key line items: current period obligation, cumulative obligation, current period expenditure, and cumulative expenditure are key line items. In addition, report corrections cannot be made after the reporting deadline unless prompted by Treasury staff. Any changes or revisions will need to be reflected in the next Project and Expenditure report. 2 CFR 200.502 states that the determination of when a federal award is expended must be based on when the activity related to the award occurs. In general, the activity pertains to events that require the nonfederal entity to comply with federal statutes, regulations, and the terms and conditions of federal awards. 2 CFR 200.303(a) states that non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. CAUSE OMB manages State and Local Fiscal Recovery Funds centrally and developed a process to reimburse agencies for their eligible expenditures once expenditures are incurred and agencies requested reimbursement. As a result, reimbursement from the state’s allocation of SLFRF moneys always occurs after the agency expenditure. Funds were included in the federal report for the period in which reimbursement to the agency occurred. In some cases, this resulted in the agency expenditure occurring in a period prior to the period covered under the quarterly SLFRF report. In addition, OMB's reporting process did not identify its own SLFRF expenditures in a timely manner. Lastly, OMB did not consistently utilize its tracking spreadsheet for reporting certain key line items. EFFECT State and Local Fiscal Recovery Funds (SLFRF) data reported to the U.S. Department of Treasury in quarterly Project and Expenditures Reports was inaccurate. CONTEXT In March 2021, the Federal Department of Treasury obligated funds to all 50 states under the State Local and Fiscal Recovery Fund to help states mitigate negative economic impacts caused by the COVID-19 pandemic. In November 2021, the special session of the 67th legislature obligated use of the majority of the funds to various agencies across the state. As the state was able to show that the revenue lost in years 2020 and 2021 exceeded the amount of the obligation from the Department of Treasury, the state was able to claim use of these funds under revenue replacement which allowed the state to utilize them for 'government operations' in addition to other specific uses and also allowing the state to report use of these funds under a single 'revenue replacement' project. The agencies began using the funds for purposes after they were obligated by the state legislature and began recording expenditures against the grant throughout our audit period. When these funds were initially disbursed to the state in March 2021, the funds were received by OMB and OMB then transferred reimbursement to agencies on request. The remainder of the funds were obligated by the state legislature during the 68th Legislative Assembly, which included any turnback funds obligated in previous legislation. North Dakota's project description on the reports was consistent and based on legislative appropriation. As reported, "Due to its extraordinary revenue loss during the pandemic, North Dakota’s entire SLFRF allocation is dedicated to project expenditure category group 6 – Revenue Replacement. Consequently, all expenditures will fall under project expenditure category 6.1 – Provision of Government Services. Government services, as defined by the North Dakota legislature, includes economic development and workforce development initiatives, infrastructure and deferred maintenance initiatives, state service delivery and information technology improvements, and healthcare and emergency response initiatives." Cumulative expenditures reported by OMB for the covered period ending June 30, 2024, totaled $686,652,130. Cumulative expenditures reported by agencies and universities on SEFAs for the same period totaled $670,946,688; however, the basis of accounting used to prepare the SEFA varies amongst the agencies and universities. The state's cumulative expenditures are expected to reconcile to the state's SLFRF allocation in its final Project and Expenditure Report. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Finding 2022-035 was reported in the immediate prior year. RECOMMENDATION We recommend the Office of Management and Budget ensure quarterly Project and Expenditure Reports accurately report the State's SLFRF obligations and expenditures to the Department of Treasury. OFFICE OF MANAGEMENT AND BUDGET RESPONSE The Office of Management agrees with this finding, but will continue federal reporting based on the timing of reimbursement of expenditures to other state agencies for the duration of the SLFRF reporting period. OMB will ensure all expenditures of SFLRF funding are accurately included in the reports based on the period of reimbursement. Because OMB is responsible for the state reporting under this program, it is necessary to maintain some level of control over these funds. Consequently, OMB manages the funds centrally and developed a process to reimburse agencies for their eligible expenditures once expenditures were incurred and agencies requested reimbursement. As a result, reimbursement from the state’s allocation of SLFRF moneys always occurs after the agency expenditure. Funds are included in the Federal report for the period in which reimbursement from the SLFRF occurs. In some cases, this results in the agency expenditure occurring in a period prior to the period covered under the quarterly SLFRF report in which the reimbursement is reported. To better track OMB expenditures of SLFRF moneys, which is a separate process from the reimbursement of other agencies, OMB will run specific expense reports for OMB agency expenditures to ensure all SLFRF expenses are reported in the proper period. See “Management’s Response and Corrective Action” section of this report. AUDITOR’S CONCLUDING COMMENTS While the Office of Management and Budget agrees with the finding, continuing Federal reporting based on the timing of reimbursed expenditures will likely cause further inaccurate SLFRF reporting. In addition, amounts transferred to agencies are not confirmed to not exceed incurred expenditures to ensure a reimbursement process is in place.
CONDITION The audit tested quarterly Project and Expenditure reports of the State and Local Fiscal Recovery Funds (SLFRF) program for the periods ending March 2023, December 2023, and June 2024. Project and Expenditure reports are prepared and submitted by the ND Office of Management and Budget. Errors in key line items in all three quarterly Project and Expenditures Reports tested were identified. Key line items with errors included current period expenditures, cumulative expenditures, and current period obligations. Current period expenditures reported on the March 2023 and December 2023 reports did not agree to the tracking spreadsheet used to prepare the report. The net unreconciled difference in current period expenditures for these quarters was $732,036. The reason for the difference included that OMB's own SLFRF expenditures were not reported in the proper period. Cumulative expenditures reported by OMB for all three covered periods did not agree to the tracking spreadsheet used to prepare the report. The state's actual cumulative expenditures were not determined since changes or revisions can be reflected in the next Project and Expenditures report. However, cumulative expenditures reported by OMB for the covered period ending June 30, 2024, totaled $686,652,130 while cumulative expenditures reported by agencies and universities on SEFAs for the same period totaled $670,946,688. The basis of accounting used to prepare the SEFA varies amongst the agencies and universities; however, the state's cumulative expenditures are expected to reconcile to the state's SLFRF allocation in its final Project and Expenditure Report. Current period obligations reported by OMB for the covered period ending June 30, 2024, totaled $93,696,726, which should have been $0. This error did not impact the cumulative obligation amount since OMB previously reported the state's SLFRF allotment was 100% obligated in the cumulative obligation amount for the covered period ending December 31, 2023. CRITERIA According to Coronavirus State and Local Fiscal Recovery Funds Compliance and Reporting Guidance, states are required to submit quarterly Project and Expenditure Reports. The 2023 and 2024 Compliance Supplements indicate the following line items are key line items: current period obligation, cumulative obligation, current period expenditure, and cumulative expenditure are key line items. In addition, report corrections cannot be made after the reporting deadline unless prompted by Treasury staff. Any changes or revisions will need to be reflected in the next Project and Expenditure report. 2 CFR 200.502 states that the determination of when a federal award is expended must be based on when the activity related to the award occurs. In general, the activity pertains to events that require the nonfederal entity to comply with federal statutes, regulations, and the terms and conditions of federal awards. 2 CFR 200.303(a) states that non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. CAUSE OMB manages State and Local Fiscal Recovery Funds centrally and developed a process to reimburse agencies for their eligible expenditures once expenditures are incurred and agencies requested reimbursement. As a result, reimbursement from the state’s allocation of SLFRF moneys always occurs after the agency expenditure. Funds were included in the federal report for the period in which reimbursement to the agency occurred. In some cases, this resulted in the agency expenditure occurring in a period prior to the period covered under the quarterly SLFRF report. In addition, OMB's reporting process did not identify its own SLFRF expenditures in a timely manner. Lastly, OMB did not consistently utilize its tracking spreadsheet for reporting certain key line items. EFFECT State and Local Fiscal Recovery Funds (SLFRF) data reported to the U.S. Department of Treasury in quarterly Project and Expenditures Reports was inaccurate. CONTEXT In March 2021, the Federal Department of Treasury obligated funds to all 50 states under the State Local and Fiscal Recovery Fund to help states mitigate negative economic impacts caused by the COVID-19 pandemic. In November 2021, the special session of the 67th legislature obligated use of the majority of the funds to various agencies across the state. As the state was able to show that the revenue lost in years 2020 and 2021 exceeded the amount of the obligation from the Department of Treasury, the state was able to claim use of these funds under revenue replacement which allowed the state to utilize them for 'government operations' in addition to other specific uses and also allowing the state to report use of these funds under a single 'revenue replacement' project. The agencies began using the funds for purposes after they were obligated by the state legislature and began recording expenditures against the grant throughout our audit period. When these funds were initially disbursed to the state in March 2021, the funds were received by OMB and OMB then transferred reimbursement to agencies on request. The remainder of the funds were obligated by the state legislature during the 68th Legislative Assembly, which included any turnback funds obligated in previous legislation. North Dakota's project description on the reports was consistent and based on legislative appropriation. As reported, "Due to its extraordinary revenue loss during the pandemic, North Dakota’s entire SLFRF allocation is dedicated to project expenditure category group 6 – Revenue Replacement. Consequently, all expenditures will fall under project expenditure category 6.1 – Provision of Government Services. Government services, as defined by the North Dakota legislature, includes economic development and workforce development initiatives, infrastructure and deferred maintenance initiatives, state service delivery and information technology improvements, and healthcare and emergency response initiatives." Cumulative expenditures reported by OMB for the covered period ending June 30, 2024, totaled $686,652,130. Cumulative expenditures reported by agencies and universities on SEFAs for the same period totaled $670,946,688; however, the basis of accounting used to prepare the SEFA varies amongst the agencies and universities. The state's cumulative expenditures are expected to reconcile to the state's SLFRF allocation in its final Project and Expenditure Report. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Finding 2022-035 was reported in the immediate prior year. RECOMMENDATION We recommend the Office of Management and Budget ensure quarterly Project and Expenditure Reports accurately report the State's SLFRF obligations and expenditures to the Department of Treasury. OFFICE OF MANAGEMENT AND BUDGET RESPONSE The Office of Management agrees with this finding, but will continue federal reporting based on the timing of reimbursement of expenditures to other state agencies for the duration of the SLFRF reporting period. OMB will ensure all expenditures of SFLRF funding are accurately included in the reports based on the period of reimbursement. Because OMB is responsible for the state reporting under this program, it is necessary to maintain some level of control over these funds. Consequently, OMB manages the funds centrally and developed a process to reimburse agencies for their eligible expenditures once expenditures were incurred and agencies requested reimbursement. As a result, reimbursement from the state’s allocation of SLFRF moneys always occurs after the agency expenditure. Funds are included in the Federal report for the period in which reimbursement from the SLFRF occurs. In some cases, this results in the agency expenditure occurring in a period prior to the period covered under the quarterly SLFRF report in which the reimbursement is reported. To better track OMB expenditures of SLFRF moneys, which is a separate process from the reimbursement of other agencies, OMB will run specific expense reports for OMB agency expenditures to ensure all SLFRF expenses are reported in the proper period. See “Management’s Response and Corrective Action” section of this report. AUDITOR’S CONCLUDING COMMENTS While the Office of Management and Budget agrees with the finding, continuing Federal reporting based on the timing of reimbursed expenditures will likely cause further inaccurate SLFRF reporting. In addition, amounts transferred to agencies are not confirmed to not exceed incurred expenditures to ensure a reimbursement process is in place.
CONDITION The audit tested quarterly Project and Expenditure reports of the State and Local Fiscal Recovery Funds (SLFRF) program for the periods ending March 2023, December 2023, and June 2024. Project and Expenditure reports are prepared and submitted by the ND Office of Management and Budget. Errors in key line items in all three quarterly Project and Expenditures Reports tested were identified. Key line items with errors included current period expenditures, cumulative expenditures, and current period obligations. Current period expenditures reported on the March 2023 and December 2023 reports did not agree to the tracking spreadsheet used to prepare the report. The net unreconciled difference in current period expenditures for these quarters was $732,036. The reason for the difference included that OMB's own SLFRF expenditures were not reported in the proper period. Cumulative expenditures reported by OMB for all three covered periods did not agree to the tracking spreadsheet used to prepare the report. The state's actual cumulative expenditures were not determined since changes or revisions can be reflected in the next Project and Expenditures report. However, cumulative expenditures reported by OMB for the covered period ending June 30, 2024, totaled $686,652,130 while cumulative expenditures reported by agencies and universities on SEFAs for the same period totaled $670,946,688. The basis of accounting used to prepare the SEFA varies amongst the agencies and universities; however, the state's cumulative expenditures are expected to reconcile to the state's SLFRF allocation in its final Project and Expenditure Report. Current period obligations reported by OMB for the covered period ending June 30, 2024, totaled $93,696,726, which should have been $0. This error did not impact the cumulative obligation amount since OMB previously reported the state's SLFRF allotment was 100% obligated in the cumulative obligation amount for the covered period ending December 31, 2023. CRITERIA According to Coronavirus State and Local Fiscal Recovery Funds Compliance and Reporting Guidance, states are required to submit quarterly Project and Expenditure Reports. The 2023 and 2024 Compliance Supplements indicate the following line items are key line items: current period obligation, cumulative obligation, current period expenditure, and cumulative expenditure are key line items. In addition, report corrections cannot be made after the reporting deadline unless prompted by Treasury staff. Any changes or revisions will need to be reflected in the next Project and Expenditure report. 2 CFR 200.502 states that the determination of when a federal award is expended must be based on when the activity related to the award occurs. In general, the activity pertains to events that require the nonfederal entity to comply with federal statutes, regulations, and the terms and conditions of federal awards. 2 CFR 200.303(a) states that non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. CAUSE OMB manages State and Local Fiscal Recovery Funds centrally and developed a process to reimburse agencies for their eligible expenditures once expenditures are incurred and agencies requested reimbursement. As a result, reimbursement from the state’s allocation of SLFRF moneys always occurs after the agency expenditure. Funds were included in the federal report for the period in which reimbursement to the agency occurred. In some cases, this resulted in the agency expenditure occurring in a period prior to the period covered under the quarterly SLFRF report. In addition, OMB's reporting process did not identify its own SLFRF expenditures in a timely manner. Lastly, OMB did not consistently utilize its tracking spreadsheet for reporting certain key line items. EFFECT State and Local Fiscal Recovery Funds (SLFRF) data reported to the U.S. Department of Treasury in quarterly Project and Expenditures Reports was inaccurate. CONTEXT In March 2021, the Federal Department of Treasury obligated funds to all 50 states under the State Local and Fiscal Recovery Fund to help states mitigate negative economic impacts caused by the COVID-19 pandemic. In November 2021, the special session of the 67th legislature obligated use of the majority of the funds to various agencies across the state. As the state was able to show that the revenue lost in years 2020 and 2021 exceeded the amount of the obligation from the Department of Treasury, the state was able to claim use of these funds under revenue replacement which allowed the state to utilize them for 'government operations' in addition to other specific uses and also allowing the state to report use of these funds under a single 'revenue replacement' project. The agencies began using the funds for purposes after they were obligated by the state legislature and began recording expenditures against the grant throughout our audit period. When these funds were initially disbursed to the state in March 2021, the funds were received by OMB and OMB then transferred reimbursement to agencies on request. The remainder of the funds were obligated by the state legislature during the 68th Legislative Assembly, which included any turnback funds obligated in previous legislation. North Dakota's project description on the reports was consistent and based on legislative appropriation. As reported, "Due to its extraordinary revenue loss during the pandemic, North Dakota’s entire SLFRF allocation is dedicated to project expenditure category group 6 – Revenue Replacement. Consequently, all expenditures will fall under project expenditure category 6.1 – Provision of Government Services. Government services, as defined by the North Dakota legislature, includes economic development and workforce development initiatives, infrastructure and deferred maintenance initiatives, state service delivery and information technology improvements, and healthcare and emergency response initiatives." Cumulative expenditures reported by OMB for the covered period ending June 30, 2024, totaled $686,652,130. Cumulative expenditures reported by agencies and universities on SEFAs for the same period totaled $670,946,688; however, the basis of accounting used to prepare the SEFA varies amongst the agencies and universities. The state's cumulative expenditures are expected to reconcile to the state's SLFRF allocation in its final Project and Expenditure Report. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Finding 2022-035 was reported in the immediate prior year. RECOMMENDATION We recommend the Office of Management and Budget ensure quarterly Project and Expenditure Reports accurately report the State's SLFRF obligations and expenditures to the Department of Treasury. OFFICE OF MANAGEMENT AND BUDGET RESPONSE The Office of Management agrees with this finding, but will continue federal reporting based on the timing of reimbursement of expenditures to other state agencies for the duration of the SLFRF reporting period. OMB will ensure all expenditures of SFLRF funding are accurately included in the reports based on the period of reimbursement. Because OMB is responsible for the state reporting under this program, it is necessary to maintain some level of control over these funds. Consequently, OMB manages the funds centrally and developed a process to reimburse agencies for their eligible expenditures once expenditures were incurred and agencies requested reimbursement. As a result, reimbursement from the state’s allocation of SLFRF moneys always occurs after the agency expenditure. Funds are included in the Federal report for the period in which reimbursement from the SLFRF occurs. In some cases, this results in the agency expenditure occurring in a period prior to the period covered under the quarterly SLFRF report in which the reimbursement is reported. To better track OMB expenditures of SLFRF moneys, which is a separate process from the reimbursement of other agencies, OMB will run specific expense reports for OMB agency expenditures to ensure all SLFRF expenses are reported in the proper period. See “Management’s Response and Corrective Action” section of this report. AUDITOR’S CONCLUDING COMMENTS While the Office of Management and Budget agrees with the finding, continuing Federal reporting based on the timing of reimbursed expenditures will likely cause further inaccurate SLFRF reporting. In addition, amounts transferred to agencies are not confirmed to not exceed incurred expenditures to ensure a reimbursement process is in place.
CONDITION The audit tested quarterly Project and Expenditure reports of the State and Local Fiscal Recovery Funds (SLFRF) program for the periods ending March 2023, December 2023, and June 2024. Project and Expenditure reports are prepared and submitted by the ND Office of Management and Budget. Errors in key line items in all three quarterly Project and Expenditures Reports tested were identified. Key line items with errors included current period expenditures, cumulative expenditures, and current period obligations. Current period expenditures reported on the March 2023 and December 2023 reports did not agree to the tracking spreadsheet used to prepare the report. The net unreconciled difference in current period expenditures for these quarters was $732,036. The reason for the difference included that OMB's own SLFRF expenditures were not reported in the proper period. Cumulative expenditures reported by OMB for all three covered periods did not agree to the tracking spreadsheet used to prepare the report. The state's actual cumulative expenditures were not determined since changes or revisions can be reflected in the next Project and Expenditures report. However, cumulative expenditures reported by OMB for the covered period ending June 30, 2024, totaled $686,652,130 while cumulative expenditures reported by agencies and universities on SEFAs for the same period totaled $670,946,688. The basis of accounting used to prepare the SEFA varies amongst the agencies and universities; however, the state's cumulative expenditures are expected to reconcile to the state's SLFRF allocation in its final Project and Expenditure Report. Current period obligations reported by OMB for the covered period ending June 30, 2024, totaled $93,696,726, which should have been $0. This error did not impact the cumulative obligation amount since OMB previously reported the state's SLFRF allotment was 100% obligated in the cumulative obligation amount for the covered period ending December 31, 2023. CRITERIA According to Coronavirus State and Local Fiscal Recovery Funds Compliance and Reporting Guidance, states are required to submit quarterly Project and Expenditure Reports. The 2023 and 2024 Compliance Supplements indicate the following line items are key line items: current period obligation, cumulative obligation, current period expenditure, and cumulative expenditure are key line items. In addition, report corrections cannot be made after the reporting deadline unless prompted by Treasury staff. Any changes or revisions will need to be reflected in the next Project and Expenditure report. 2 CFR 200.502 states that the determination of when a federal award is expended must be based on when the activity related to the award occurs. In general, the activity pertains to events that require the nonfederal entity to comply with federal statutes, regulations, and the terms and conditions of federal awards. 2 CFR 200.303(a) states that non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. CAUSE OMB manages State and Local Fiscal Recovery Funds centrally and developed a process to reimburse agencies for their eligible expenditures once expenditures are incurred and agencies requested reimbursement. As a result, reimbursement from the state’s allocation of SLFRF moneys always occurs after the agency expenditure. Funds were included in the federal report for the period in which reimbursement to the agency occurred. In some cases, this resulted in the agency expenditure occurring in a period prior to the period covered under the quarterly SLFRF report. In addition, OMB's reporting process did not identify its own SLFRF expenditures in a timely manner. Lastly, OMB did not consistently utilize its tracking spreadsheet for reporting certain key line items. EFFECT State and Local Fiscal Recovery Funds (SLFRF) data reported to the U.S. Department of Treasury in quarterly Project and Expenditures Reports was inaccurate. CONTEXT In March 2021, the Federal Department of Treasury obligated funds to all 50 states under the State Local and Fiscal Recovery Fund to help states mitigate negative economic impacts caused by the COVID-19 pandemic. In November 2021, the special session of the 67th legislature obligated use of the majority of the funds to various agencies across the state. As the state was able to show that the revenue lost in years 2020 and 2021 exceeded the amount of the obligation from the Department of Treasury, the state was able to claim use of these funds under revenue replacement which allowed the state to utilize them for 'government operations' in addition to other specific uses and also allowing the state to report use of these funds under a single 'revenue replacement' project. The agencies began using the funds for purposes after they were obligated by the state legislature and began recording expenditures against the grant throughout our audit period. When these funds were initially disbursed to the state in March 2021, the funds were received by OMB and OMB then transferred reimbursement to agencies on request. The remainder of the funds were obligated by the state legislature during the 68th Legislative Assembly, which included any turnback funds obligated in previous legislation. North Dakota's project description on the reports was consistent and based on legislative appropriation. As reported, "Due to its extraordinary revenue loss during the pandemic, North Dakota’s entire SLFRF allocation is dedicated to project expenditure category group 6 – Revenue Replacement. Consequently, all expenditures will fall under project expenditure category 6.1 – Provision of Government Services. Government services, as defined by the North Dakota legislature, includes economic development and workforce development initiatives, infrastructure and deferred maintenance initiatives, state service delivery and information technology improvements, and healthcare and emergency response initiatives." Cumulative expenditures reported by OMB for the covered period ending June 30, 2024, totaled $686,652,130. Cumulative expenditures reported by agencies and universities on SEFAs for the same period totaled $670,946,688; however, the basis of accounting used to prepare the SEFA varies amongst the agencies and universities. The state's cumulative expenditures are expected to reconcile to the state's SLFRF allocation in its final Project and Expenditure Report. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Finding 2022-035 was reported in the immediate prior year. RECOMMENDATION We recommend the Office of Management and Budget ensure quarterly Project and Expenditure Reports accurately report the State's SLFRF obligations and expenditures to the Department of Treasury. OFFICE OF MANAGEMENT AND BUDGET RESPONSE The Office of Management agrees with this finding, but will continue federal reporting based on the timing of reimbursement of expenditures to other state agencies for the duration of the SLFRF reporting period. OMB will ensure all expenditures of SFLRF funding are accurately included in the reports based on the period of reimbursement. Because OMB is responsible for the state reporting under this program, it is necessary to maintain some level of control over these funds. Consequently, OMB manages the funds centrally and developed a process to reimburse agencies for their eligible expenditures once expenditures were incurred and agencies requested reimbursement. As a result, reimbursement from the state’s allocation of SLFRF moneys always occurs after the agency expenditure. Funds are included in the Federal report for the period in which reimbursement from the SLFRF occurs. In some cases, this results in the agency expenditure occurring in a period prior to the period covered under the quarterly SLFRF report in which the reimbursement is reported. To better track OMB expenditures of SLFRF moneys, which is a separate process from the reimbursement of other agencies, OMB will run specific expense reports for OMB agency expenditures to ensure all SLFRF expenses are reported in the proper period. See “Management’s Response and Corrective Action” section of this report. AUDITOR’S CONCLUDING COMMENTS While the Office of Management and Budget agrees with the finding, continuing Federal reporting based on the timing of reimbursed expenditures will likely cause further inaccurate SLFRF reporting. In addition, amounts transferred to agencies are not confirmed to not exceed incurred expenditures to ensure a reimbursement process is in place.
CONDITION The audit tested quarterly Project and Expenditure reports of the State and Local Fiscal Recovery Funds (SLFRF) program for the periods ending March 2023, December 2023, and June 2024. Project and Expenditure reports are prepared and submitted by the ND Office of Management and Budget. Errors in key line items in all three quarterly Project and Expenditures Reports tested were identified. Key line items with errors included current period expenditures, cumulative expenditures, and current period obligations. Current period expenditures reported on the March 2023 and December 2023 reports did not agree to the tracking spreadsheet used to prepare the report. The net unreconciled difference in current period expenditures for these quarters was $732,036. The reason for the difference included that OMB's own SLFRF expenditures were not reported in the proper period. Cumulative expenditures reported by OMB for all three covered periods did not agree to the tracking spreadsheet used to prepare the report. The state's actual cumulative expenditures were not determined since changes or revisions can be reflected in the next Project and Expenditures report. However, cumulative expenditures reported by OMB for the covered period ending June 30, 2024, totaled $686,652,130 while cumulative expenditures reported by agencies and universities on SEFAs for the same period totaled $670,946,688. The basis of accounting used to prepare the SEFA varies amongst the agencies and universities; however, the state's cumulative expenditures are expected to reconcile to the state's SLFRF allocation in its final Project and Expenditure Report. Current period obligations reported by OMB for the covered period ending June 30, 2024, totaled $93,696,726, which should have been $0. This error did not impact the cumulative obligation amount since OMB previously reported the state's SLFRF allotment was 100% obligated in the cumulative obligation amount for the covered period ending December 31, 2023. CRITERIA According to Coronavirus State and Local Fiscal Recovery Funds Compliance and Reporting Guidance, states are required to submit quarterly Project and Expenditure Reports. The 2023 and 2024 Compliance Supplements indicate the following line items are key line items: current period obligation, cumulative obligation, current period expenditure, and cumulative expenditure are key line items. In addition, report corrections cannot be made after the reporting deadline unless prompted by Treasury staff. Any changes or revisions will need to be reflected in the next Project and Expenditure report. 2 CFR 200.502 states that the determination of when a federal award is expended must be based on when the activity related to the award occurs. In general, the activity pertains to events that require the nonfederal entity to comply with federal statutes, regulations, and the terms and conditions of federal awards. 2 CFR 200.303(a) states that non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. CAUSE OMB manages State and Local Fiscal Recovery Funds centrally and developed a process to reimburse agencies for their eligible expenditures once expenditures are incurred and agencies requested reimbursement. As a result, reimbursement from the state’s allocation of SLFRF moneys always occurs after the agency expenditure. Funds were included in the federal report for the period in which reimbursement to the agency occurred. In some cases, this resulted in the agency expenditure occurring in a period prior to the period covered under the quarterly SLFRF report. In addition, OMB's reporting process did not identify its own SLFRF expenditures in a timely manner. Lastly, OMB did not consistently utilize its tracking spreadsheet for reporting certain key line items. EFFECT State and Local Fiscal Recovery Funds (SLFRF) data reported to the U.S. Department of Treasury in quarterly Project and Expenditures Reports was inaccurate. CONTEXT In March 2021, the Federal Department of Treasury obligated funds to all 50 states under the State Local and Fiscal Recovery Fund to help states mitigate negative economic impacts caused by the COVID-19 pandemic. In November 2021, the special session of the 67th legislature obligated use of the majority of the funds to various agencies across the state. As the state was able to show that the revenue lost in years 2020 and 2021 exceeded the amount of the obligation from the Department of Treasury, the state was able to claim use of these funds under revenue replacement which allowed the state to utilize them for 'government operations' in addition to other specific uses and also allowing the state to report use of these funds under a single 'revenue replacement' project. The agencies began using the funds for purposes after they were obligated by the state legislature and began recording expenditures against the grant throughout our audit period. When these funds were initially disbursed to the state in March 2021, the funds were received by OMB and OMB then transferred reimbursement to agencies on request. The remainder of the funds were obligated by the state legislature during the 68th Legislative Assembly, which included any turnback funds obligated in previous legislation. North Dakota's project description on the reports was consistent and based on legislative appropriation. As reported, "Due to its extraordinary revenue loss during the pandemic, North Dakota’s entire SLFRF allocation is dedicated to project expenditure category group 6 – Revenue Replacement. Consequently, all expenditures will fall under project expenditure category 6.1 – Provision of Government Services. Government services, as defined by the North Dakota legislature, includes economic development and workforce development initiatives, infrastructure and deferred maintenance initiatives, state service delivery and information technology improvements, and healthcare and emergency response initiatives." Cumulative expenditures reported by OMB for the covered period ending June 30, 2024, totaled $686,652,130. Cumulative expenditures reported by agencies and universities on SEFAs for the same period totaled $670,946,688; however, the basis of accounting used to prepare the SEFA varies amongst the agencies and universities. The state's cumulative expenditures are expected to reconcile to the state's SLFRF allocation in its final Project and Expenditure Report. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Finding 2022-035 was reported in the immediate prior year. RECOMMENDATION We recommend the Office of Management and Budget ensure quarterly Project and Expenditure Reports accurately report the State's SLFRF obligations and expenditures to the Department of Treasury. OFFICE OF MANAGEMENT AND BUDGET RESPONSE The Office of Management agrees with this finding, but will continue federal reporting based on the timing of reimbursement of expenditures to other state agencies for the duration of the SLFRF reporting period. OMB will ensure all expenditures of SFLRF funding are accurately included in the reports based on the period of reimbursement. Because OMB is responsible for the state reporting under this program, it is necessary to maintain some level of control over these funds. Consequently, OMB manages the funds centrally and developed a process to reimburse agencies for their eligible expenditures once expenditures were incurred and agencies requested reimbursement. As a result, reimbursement from the state’s allocation of SLFRF moneys always occurs after the agency expenditure. Funds are included in the Federal report for the period in which reimbursement from the SLFRF occurs. In some cases, this results in the agency expenditure occurring in a period prior to the period covered under the quarterly SLFRF report in which the reimbursement is reported. To better track OMB expenditures of SLFRF moneys, which is a separate process from the reimbursement of other agencies, OMB will run specific expense reports for OMB agency expenditures to ensure all SLFRF expenses are reported in the proper period. See “Management’s Response and Corrective Action” section of this report. AUDITOR’S CONCLUDING COMMENTS While the Office of Management and Budget agrees with the finding, continuing Federal reporting based on the timing of reimbursed expenditures will likely cause further inaccurate SLFRF reporting. In addition, amounts transferred to agencies are not confirmed to not exceed incurred expenditures to ensure a reimbursement process is in place.
CONDITION The audit tested quarterly Project and Expenditure reports of the State and Local Fiscal Recovery Funds (SLFRF) program for the periods ending March 2023, December 2023, and June 2024. Project and Expenditure reports are prepared and submitted by the ND Office of Management and Budget. Errors in key line items in all three quarterly Project and Expenditures Reports tested were identified. Key line items with errors included current period expenditures, cumulative expenditures, and current period obligations. Current period expenditures reported on the March 2023 and December 2023 reports did not agree to the tracking spreadsheet used to prepare the report. The net unreconciled difference in current period expenditures for these quarters was $732,036. The reason for the difference included that OMB's own SLFRF expenditures were not reported in the proper period. Cumulative expenditures reported by OMB for all three covered periods did not agree to the tracking spreadsheet used to prepare the report. The state's actual cumulative expenditures were not determined since changes or revisions can be reflected in the next Project and Expenditures report. However, cumulative expenditures reported by OMB for the covered period ending June 30, 2024, totaled $686,652,130 while cumulative expenditures reported by agencies and universities on SEFAs for the same period totaled $670,946,688. The basis of accounting used to prepare the SEFA varies amongst the agencies and universities; however, the state's cumulative expenditures are expected to reconcile to the state's SLFRF allocation in its final Project and Expenditure Report. Current period obligations reported by OMB for the covered period ending June 30, 2024, totaled $93,696,726, which should have been $0. This error did not impact the cumulative obligation amount since OMB previously reported the state's SLFRF allotment was 100% obligated in the cumulative obligation amount for the covered period ending December 31, 2023. CRITERIA According to Coronavirus State and Local Fiscal Recovery Funds Compliance and Reporting Guidance, states are required to submit quarterly Project and Expenditure Reports. The 2023 and 2024 Compliance Supplements indicate the following line items are key line items: current period obligation, cumulative obligation, current period expenditure, and cumulative expenditure are key line items. In addition, report corrections cannot be made after the reporting deadline unless prompted by Treasury staff. Any changes or revisions will need to be reflected in the next Project and Expenditure report. 2 CFR 200.502 states that the determination of when a federal award is expended must be based on when the activity related to the award occurs. In general, the activity pertains to events that require the nonfederal entity to comply with federal statutes, regulations, and the terms and conditions of federal awards. 2 CFR 200.303(a) states that non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. CAUSE OMB manages State and Local Fiscal Recovery Funds centrally and developed a process to reimburse agencies for their eligible expenditures once expenditures are incurred and agencies requested reimbursement. As a result, reimbursement from the state’s allocation of SLFRF moneys always occurs after the agency expenditure. Funds were included in the federal report for the period in which reimbursement to the agency occurred. In some cases, this resulted in the agency expenditure occurring in a period prior to the period covered under the quarterly SLFRF report. In addition, OMB's reporting process did not identify its own SLFRF expenditures in a timely manner. Lastly, OMB did not consistently utilize its tracking spreadsheet for reporting certain key line items. EFFECT State and Local Fiscal Recovery Funds (SLFRF) data reported to the U.S. Department of Treasury in quarterly Project and Expenditures Reports was inaccurate. CONTEXT In March 2021, the Federal Department of Treasury obligated funds to all 50 states under the State Local and Fiscal Recovery Fund to help states mitigate negative economic impacts caused by the COVID-19 pandemic. In November 2021, the special session of the 67th legislature obligated use of the majority of the funds to various agencies across the state. As the state was able to show that the revenue lost in years 2020 and 2021 exceeded the amount of the obligation from the Department of Treasury, the state was able to claim use of these funds under revenue replacement which allowed the state to utilize them for 'government operations' in addition to other specific uses and also allowing the state to report use of these funds under a single 'revenue replacement' project. The agencies began using the funds for purposes after they were obligated by the state legislature and began recording expenditures against the grant throughout our audit period. When these funds were initially disbursed to the state in March 2021, the funds were received by OMB and OMB then transferred reimbursement to agencies on request. The remainder of the funds were obligated by the state legislature during the 68th Legislative Assembly, which included any turnback funds obligated in previous legislation. North Dakota's project description on the reports was consistent and based on legislative appropriation. As reported, "Due to its extraordinary revenue loss during the pandemic, North Dakota’s entire SLFRF allocation is dedicated to project expenditure category group 6 – Revenue Replacement. Consequently, all expenditures will fall under project expenditure category 6.1 – Provision of Government Services. Government services, as defined by the North Dakota legislature, includes economic development and workforce development initiatives, infrastructure and deferred maintenance initiatives, state service delivery and information technology improvements, and healthcare and emergency response initiatives." Cumulative expenditures reported by OMB for the covered period ending June 30, 2024, totaled $686,652,130. Cumulative expenditures reported by agencies and universities on SEFAs for the same period totaled $670,946,688; however, the basis of accounting used to prepare the SEFA varies amongst the agencies and universities. The state's cumulative expenditures are expected to reconcile to the state's SLFRF allocation in its final Project and Expenditure Report. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Finding 2022-035 was reported in the immediate prior year. RECOMMENDATION We recommend the Office of Management and Budget ensure quarterly Project and Expenditure Reports accurately report the State's SLFRF obligations and expenditures to the Department of Treasury. OFFICE OF MANAGEMENT AND BUDGET RESPONSE The Office of Management agrees with this finding, but will continue federal reporting based on the timing of reimbursement of expenditures to other state agencies for the duration of the SLFRF reporting period. OMB will ensure all expenditures of SFLRF funding are accurately included in the reports based on the period of reimbursement. Because OMB is responsible for the state reporting under this program, it is necessary to maintain some level of control over these funds. Consequently, OMB manages the funds centrally and developed a process to reimburse agencies for their eligible expenditures once expenditures were incurred and agencies requested reimbursement. As a result, reimbursement from the state’s allocation of SLFRF moneys always occurs after the agency expenditure. Funds are included in the Federal report for the period in which reimbursement from the SLFRF occurs. In some cases, this results in the agency expenditure occurring in a period prior to the period covered under the quarterly SLFRF report in which the reimbursement is reported. To better track OMB expenditures of SLFRF moneys, which is a separate process from the reimbursement of other agencies, OMB will run specific expense reports for OMB agency expenditures to ensure all SLFRF expenses are reported in the proper period. See “Management’s Response and Corrective Action” section of this report. AUDITOR’S CONCLUDING COMMENTS While the Office of Management and Budget agrees with the finding, continuing Federal reporting based on the timing of reimbursed expenditures will likely cause further inaccurate SLFRF reporting. In addition, amounts transferred to agencies are not confirmed to not exceed incurred expenditures to ensure a reimbursement process is in place.
CONDITION The audit tested quarterly Project and Expenditure reports of the State and Local Fiscal Recovery Funds (SLFRF) program for the periods ending March 2023, December 2023, and June 2024. Project and Expenditure reports are prepared and submitted by the ND Office of Management and Budget. Errors in key line items in all three quarterly Project and Expenditures Reports tested were identified. Key line items with errors included current period expenditures, cumulative expenditures, and current period obligations. Current period expenditures reported on the March 2023 and December 2023 reports did not agree to the tracking spreadsheet used to prepare the report. The net unreconciled difference in current period expenditures for these quarters was $732,036. The reason for the difference included that OMB's own SLFRF expenditures were not reported in the proper period. Cumulative expenditures reported by OMB for all three covered periods did not agree to the tracking spreadsheet used to prepare the report. The state's actual cumulative expenditures were not determined since changes or revisions can be reflected in the next Project and Expenditures report. However, cumulative expenditures reported by OMB for the covered period ending June 30, 2024, totaled $686,652,130 while cumulative expenditures reported by agencies and universities on SEFAs for the same period totaled $670,946,688. The basis of accounting used to prepare the SEFA varies amongst the agencies and universities; however, the state's cumulative expenditures are expected to reconcile to the state's SLFRF allocation in its final Project and Expenditure Report. Current period obligations reported by OMB for the covered period ending June 30, 2024, totaled $93,696,726, which should have been $0. This error did not impact the cumulative obligation amount since OMB previously reported the state's SLFRF allotment was 100% obligated in the cumulative obligation amount for the covered period ending December 31, 2023. CRITERIA According to Coronavirus State and Local Fiscal Recovery Funds Compliance and Reporting Guidance, states are required to submit quarterly Project and Expenditure Reports. The 2023 and 2024 Compliance Supplements indicate the following line items are key line items: current period obligation, cumulative obligation, current period expenditure, and cumulative expenditure are key line items. In addition, report corrections cannot be made after the reporting deadline unless prompted by Treasury staff. Any changes or revisions will need to be reflected in the next Project and Expenditure report. 2 CFR 200.502 states that the determination of when a federal award is expended must be based on when the activity related to the award occurs. In general, the activity pertains to events that require the nonfederal entity to comply with federal statutes, regulations, and the terms and conditions of federal awards. 2 CFR 200.303(a) states that non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. CAUSE OMB manages State and Local Fiscal Recovery Funds centrally and developed a process to reimburse agencies for their eligible expenditures once expenditures are incurred and agencies requested reimbursement. As a result, reimbursement from the state’s allocation of SLFRF moneys always occurs after the agency expenditure. Funds were included in the federal report for the period in which reimbursement to the agency occurred. In some cases, this resulted in the agency expenditure occurring in a period prior to the period covered under the quarterly SLFRF report. In addition, OMB's reporting process did not identify its own SLFRF expenditures in a timely manner. Lastly, OMB did not consistently utilize its tracking spreadsheet for reporting certain key line items. EFFECT State and Local Fiscal Recovery Funds (SLFRF) data reported to the U.S. Department of Treasury in quarterly Project and Expenditures Reports was inaccurate. CONTEXT In March 2021, the Federal Department of Treasury obligated funds to all 50 states under the State Local and Fiscal Recovery Fund to help states mitigate negative economic impacts caused by the COVID-19 pandemic. In November 2021, the special session of the 67th legislature obligated use of the majority of the funds to various agencies across the state. As the state was able to show that the revenue lost in years 2020 and 2021 exceeded the amount of the obligation from the Department of Treasury, the state was able to claim use of these funds under revenue replacement which allowed the state to utilize them for 'government operations' in addition to other specific uses and also allowing the state to report use of these funds under a single 'revenue replacement' project. The agencies began using the funds for purposes after they were obligated by the state legislature and began recording expenditures against the grant throughout our audit period. When these funds were initially disbursed to the state in March 2021, the funds were received by OMB and OMB then transferred reimbursement to agencies on request. The remainder of the funds were obligated by the state legislature during the 68th Legislative Assembly, which included any turnback funds obligated in previous legislation. North Dakota's project description on the reports was consistent and based on legislative appropriation. As reported, "Due to its extraordinary revenue loss during the pandemic, North Dakota’s entire SLFRF allocation is dedicated to project expenditure category group 6 – Revenue Replacement. Consequently, all expenditures will fall under project expenditure category 6.1 – Provision of Government Services. Government services, as defined by the North Dakota legislature, includes economic development and workforce development initiatives, infrastructure and deferred maintenance initiatives, state service delivery and information technology improvements, and healthcare and emergency response initiatives." Cumulative expenditures reported by OMB for the covered period ending June 30, 2024, totaled $686,652,130. Cumulative expenditures reported by agencies and universities on SEFAs for the same period totaled $670,946,688; however, the basis of accounting used to prepare the SEFA varies amongst the agencies and universities. The state's cumulative expenditures are expected to reconcile to the state's SLFRF allocation in its final Project and Expenditure Report. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Finding 2022-035 was reported in the immediate prior year. RECOMMENDATION We recommend the Office of Management and Budget ensure quarterly Project and Expenditure Reports accurately report the State's SLFRF obligations and expenditures to the Department of Treasury. OFFICE OF MANAGEMENT AND BUDGET RESPONSE The Office of Management agrees with this finding, but will continue federal reporting based on the timing of reimbursement of expenditures to other state agencies for the duration of the SLFRF reporting period. OMB will ensure all expenditures of SFLRF funding are accurately included in the reports based on the period of reimbursement. Because OMB is responsible for the state reporting under this program, it is necessary to maintain some level of control over these funds. Consequently, OMB manages the funds centrally and developed a process to reimburse agencies for their eligible expenditures once expenditures were incurred and agencies requested reimbursement. As a result, reimbursement from the state’s allocation of SLFRF moneys always occurs after the agency expenditure. Funds are included in the Federal report for the period in which reimbursement from the SLFRF occurs. In some cases, this results in the agency expenditure occurring in a period prior to the period covered under the quarterly SLFRF report in which the reimbursement is reported. To better track OMB expenditures of SLFRF moneys, which is a separate process from the reimbursement of other agencies, OMB will run specific expense reports for OMB agency expenditures to ensure all SLFRF expenses are reported in the proper period. See “Management’s Response and Corrective Action” section of this report. AUDITOR’S CONCLUDING COMMENTS While the Office of Management and Budget agrees with the finding, continuing Federal reporting based on the timing of reimbursed expenditures will likely cause further inaccurate SLFRF reporting. In addition, amounts transferred to agencies are not confirmed to not exceed incurred expenditures to ensure a reimbursement process is in place.
CONDITION The audit tested quarterly Project and Expenditure reports of the State and Local Fiscal Recovery Funds (SLFRF) program for the periods ending March 2023, December 2023, and June 2024. Project and Expenditure reports are prepared and submitted by the ND Office of Management and Budget. Errors in key line items in all three quarterly Project and Expenditures Reports tested were identified. Key line items with errors included current period expenditures, cumulative expenditures, and current period obligations. Current period expenditures reported on the March 2023 and December 2023 reports did not agree to the tracking spreadsheet used to prepare the report. The net unreconciled difference in current period expenditures for these quarters was $732,036. The reason for the difference included that OMB's own SLFRF expenditures were not reported in the proper period. Cumulative expenditures reported by OMB for all three covered periods did not agree to the tracking spreadsheet used to prepare the report. The state's actual cumulative expenditures were not determined since changes or revisions can be reflected in the next Project and Expenditures report. However, cumulative expenditures reported by OMB for the covered period ending June 30, 2024, totaled $686,652,130 while cumulative expenditures reported by agencies and universities on SEFAs for the same period totaled $670,946,688. The basis of accounting used to prepare the SEFA varies amongst the agencies and universities; however, the state's cumulative expenditures are expected to reconcile to the state's SLFRF allocation in its final Project and Expenditure Report. Current period obligations reported by OMB for the covered period ending June 30, 2024, totaled $93,696,726, which should have been $0. This error did not impact the cumulative obligation amount since OMB previously reported the state's SLFRF allotment was 100% obligated in the cumulative obligation amount for the covered period ending December 31, 2023. CRITERIA According to Coronavirus State and Local Fiscal Recovery Funds Compliance and Reporting Guidance, states are required to submit quarterly Project and Expenditure Reports. The 2023 and 2024 Compliance Supplements indicate the following line items are key line items: current period obligation, cumulative obligation, current period expenditure, and cumulative expenditure are key line items. In addition, report corrections cannot be made after the reporting deadline unless prompted by Treasury staff. Any changes or revisions will need to be reflected in the next Project and Expenditure report. 2 CFR 200.502 states that the determination of when a federal award is expended must be based on when the activity related to the award occurs. In general, the activity pertains to events that require the nonfederal entity to comply with federal statutes, regulations, and the terms and conditions of federal awards. 2 CFR 200.303(a) states that non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. CAUSE OMB manages State and Local Fiscal Recovery Funds centrally and developed a process to reimburse agencies for their eligible expenditures once expenditures are incurred and agencies requested reimbursement. As a result, reimbursement from the state’s allocation of SLFRF moneys always occurs after the agency expenditure. Funds were included in the federal report for the period in which reimbursement to the agency occurred. In some cases, this resulted in the agency expenditure occurring in a period prior to the period covered under the quarterly SLFRF report. In addition, OMB's reporting process did not identify its own SLFRF expenditures in a timely manner. Lastly, OMB did not consistently utilize its tracking spreadsheet for reporting certain key line items. EFFECT State and Local Fiscal Recovery Funds (SLFRF) data reported to the U.S. Department of Treasury in quarterly Project and Expenditures Reports was inaccurate. CONTEXT In March 2021, the Federal Department of Treasury obligated funds to all 50 states under the State Local and Fiscal Recovery Fund to help states mitigate negative economic impacts caused by the COVID-19 pandemic. In November 2021, the special session of the 67th legislature obligated use of the majority of the funds to various agencies across the state. As the state was able to show that the revenue lost in years 2020 and 2021 exceeded the amount of the obligation from the Department of Treasury, the state was able to claim use of these funds under revenue replacement which allowed the state to utilize them for 'government operations' in addition to other specific uses and also allowing the state to report use of these funds under a single 'revenue replacement' project. The agencies began using the funds for purposes after they were obligated by the state legislature and began recording expenditures against the grant throughout our audit period. When these funds were initially disbursed to the state in March 2021, the funds were received by OMB and OMB then transferred reimbursement to agencies on request. The remainder of the funds were obligated by the state legislature during the 68th Legislative Assembly, which included any turnback funds obligated in previous legislation. North Dakota's project description on the reports was consistent and based on legislative appropriation. As reported, "Due to its extraordinary revenue loss during the pandemic, North Dakota’s entire SLFRF allocation is dedicated to project expenditure category group 6 – Revenue Replacement. Consequently, all expenditures will fall under project expenditure category 6.1 – Provision of Government Services. Government services, as defined by the North Dakota legislature, includes economic development and workforce development initiatives, infrastructure and deferred maintenance initiatives, state service delivery and information technology improvements, and healthcare and emergency response initiatives." Cumulative expenditures reported by OMB for the covered period ending June 30, 2024, totaled $686,652,130. Cumulative expenditures reported by agencies and universities on SEFAs for the same period totaled $670,946,688; however, the basis of accounting used to prepare the SEFA varies amongst the agencies and universities. The state's cumulative expenditures are expected to reconcile to the state's SLFRF allocation in its final Project and Expenditure Report. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Finding 2022-035 was reported in the immediate prior year. RECOMMENDATION We recommend the Office of Management and Budget ensure quarterly Project and Expenditure Reports accurately report the State's SLFRF obligations and expenditures to the Department of Treasury. OFFICE OF MANAGEMENT AND BUDGET RESPONSE The Office of Management agrees with this finding, but will continue federal reporting based on the timing of reimbursement of expenditures to other state agencies for the duration of the SLFRF reporting period. OMB will ensure all expenditures of SFLRF funding are accurately included in the reports based on the period of reimbursement. Because OMB is responsible for the state reporting under this program, it is necessary to maintain some level of control over these funds. Consequently, OMB manages the funds centrally and developed a process to reimburse agencies for their eligible expenditures once expenditures were incurred and agencies requested reimbursement. As a result, reimbursement from the state’s allocation of SLFRF moneys always occurs after the agency expenditure. Funds are included in the Federal report for the period in which reimbursement from the SLFRF occurs. In some cases, this results in the agency expenditure occurring in a period prior to the period covered under the quarterly SLFRF report in which the reimbursement is reported. To better track OMB expenditures of SLFRF moneys, which is a separate process from the reimbursement of other agencies, OMB will run specific expense reports for OMB agency expenditures to ensure all SLFRF expenses are reported in the proper period. See “Management’s Response and Corrective Action” section of this report. AUDITOR’S CONCLUDING COMMENTS While the Office of Management and Budget agrees with the finding, continuing Federal reporting based on the timing of reimbursed expenditures will likely cause further inaccurate SLFRF reporting. In addition, amounts transferred to agencies are not confirmed to not exceed incurred expenditures to ensure a reimbursement process is in place.
CONDITION The audit tested quarterly Project and Expenditure reports of the State and Local Fiscal Recovery Funds (SLFRF) program for the periods ending March 2023, December 2023, and June 2024. Project and Expenditure reports are prepared and submitted by the ND Office of Management and Budget. Errors in key line items in all three quarterly Project and Expenditures Reports tested were identified. Key line items with errors included current period expenditures, cumulative expenditures, and current period obligations. Current period expenditures reported on the March 2023 and December 2023 reports did not agree to the tracking spreadsheet used to prepare the report. The net unreconciled difference in current period expenditures for these quarters was $732,036. The reason for the difference included that OMB's own SLFRF expenditures were not reported in the proper period. Cumulative expenditures reported by OMB for all three covered periods did not agree to the tracking spreadsheet used to prepare the report. The state's actual cumulative expenditures were not determined since changes or revisions can be reflected in the next Project and Expenditures report. However, cumulative expenditures reported by OMB for the covered period ending June 30, 2024, totaled $686,652,130 while cumulative expenditures reported by agencies and universities on SEFAs for the same period totaled $670,946,688. The basis of accounting used to prepare the SEFA varies amongst the agencies and universities; however, the state's cumulative expenditures are expected to reconcile to the state's SLFRF allocation in its final Project and Expenditure Report. Current period obligations reported by OMB for the covered period ending June 30, 2024, totaled $93,696,726, which should have been $0. This error did not impact the cumulative obligation amount since OMB previously reported the state's SLFRF allotment was 100% obligated in the cumulative obligation amount for the covered period ending December 31, 2023. CRITERIA According to Coronavirus State and Local Fiscal Recovery Funds Compliance and Reporting Guidance, states are required to submit quarterly Project and Expenditure Reports. The 2023 and 2024 Compliance Supplements indicate the following line items are key line items: current period obligation, cumulative obligation, current period expenditure, and cumulative expenditure are key line items. In addition, report corrections cannot be made after the reporting deadline unless prompted by Treasury staff. Any changes or revisions will need to be reflected in the next Project and Expenditure report. 2 CFR 200.502 states that the determination of when a federal award is expended must be based on when the activity related to the award occurs. In general, the activity pertains to events that require the nonfederal entity to comply with federal statutes, regulations, and the terms and conditions of federal awards. 2 CFR 200.303(a) states that non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. CAUSE OMB manages State and Local Fiscal Recovery Funds centrally and developed a process to reimburse agencies for their eligible expenditures once expenditures are incurred and agencies requested reimbursement. As a result, reimbursement from the state’s allocation of SLFRF moneys always occurs after the agency expenditure. Funds were included in the federal report for the period in which reimbursement to the agency occurred. In some cases, this resulted in the agency expenditure occurring in a period prior to the period covered under the quarterly SLFRF report. In addition, OMB's reporting process did not identify its own SLFRF expenditures in a timely manner. Lastly, OMB did not consistently utilize its tracking spreadsheet for reporting certain key line items. EFFECT State and Local Fiscal Recovery Funds (SLFRF) data reported to the U.S. Department of Treasury in quarterly Project and Expenditures Reports was inaccurate. CONTEXT In March 2021, the Federal Department of Treasury obligated funds to all 50 states under the State Local and Fiscal Recovery Fund to help states mitigate negative economic impacts caused by the COVID-19 pandemic. In November 2021, the special session of the 67th legislature obligated use of the majority of the funds to various agencies across the state. As the state was able to show that the revenue lost in years 2020 and 2021 exceeded the amount of the obligation from the Department of Treasury, the state was able to claim use of these funds under revenue replacement which allowed the state to utilize them for 'government operations' in addition to other specific uses and also allowing the state to report use of these funds under a single 'revenue replacement' project. The agencies began using the funds for purposes after they were obligated by the state legislature and began recording expenditures against the grant throughout our audit period. When these funds were initially disbursed to the state in March 2021, the funds were received by OMB and OMB then transferred reimbursement to agencies on request. The remainder of the funds were obligated by the state legislature during the 68th Legislative Assembly, which included any turnback funds obligated in previous legislation. North Dakota's project description on the reports was consistent and based on legislative appropriation. As reported, "Due to its extraordinary revenue loss during the pandemic, North Dakota’s entire SLFRF allocation is dedicated to project expenditure category group 6 – Revenue Replacement. Consequently, all expenditures will fall under project expenditure category 6.1 – Provision of Government Services. Government services, as defined by the North Dakota legislature, includes economic development and workforce development initiatives, infrastructure and deferred maintenance initiatives, state service delivery and information technology improvements, and healthcare and emergency response initiatives." Cumulative expenditures reported by OMB for the covered period ending June 30, 2024, totaled $686,652,130. Cumulative expenditures reported by agencies and universities on SEFAs for the same period totaled $670,946,688; however, the basis of accounting used to prepare the SEFA varies amongst the agencies and universities. The state's cumulative expenditures are expected to reconcile to the state's SLFRF allocation in its final Project and Expenditure Report. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Finding 2022-035 was reported in the immediate prior year. RECOMMENDATION We recommend the Office of Management and Budget ensure quarterly Project and Expenditure Reports accurately report the State's SLFRF obligations and expenditures to the Department of Treasury. OFFICE OF MANAGEMENT AND BUDGET RESPONSE The Office of Management agrees with this finding, but will continue federal reporting based on the timing of reimbursement of expenditures to other state agencies for the duration of the SLFRF reporting period. OMB will ensure all expenditures of SFLRF funding are accurately included in the reports based on the period of reimbursement. Because OMB is responsible for the state reporting under this program, it is necessary to maintain some level of control over these funds. Consequently, OMB manages the funds centrally and developed a process to reimburse agencies for their eligible expenditures once expenditures were incurred and agencies requested reimbursement. As a result, reimbursement from the state’s allocation of SLFRF moneys always occurs after the agency expenditure. Funds are included in the Federal report for the period in which reimbursement from the SLFRF occurs. In some cases, this results in the agency expenditure occurring in a period prior to the period covered under the quarterly SLFRF report in which the reimbursement is reported. To better track OMB expenditures of SLFRF moneys, which is a separate process from the reimbursement of other agencies, OMB will run specific expense reports for OMB agency expenditures to ensure all SLFRF expenses are reported in the proper period. See “Management’s Response and Corrective Action” section of this report. AUDITOR’S CONCLUDING COMMENTS While the Office of Management and Budget agrees with the finding, continuing Federal reporting based on the timing of reimbursed expenditures will likely cause further inaccurate SLFRF reporting. In addition, amounts transferred to agencies are not confirmed to not exceed incurred expenditures to ensure a reimbursement process is in place.
CONDITION The audit tested quarterly Project and Expenditure reports of the State and Local Fiscal Recovery Funds (SLFRF) program for the periods ending March 2023, December 2023, and June 2024. Project and Expenditure reports are prepared and submitted by the ND Office of Management and Budget. Errors in key line items in all three quarterly Project and Expenditures Reports tested were identified. Key line items with errors included current period expenditures, cumulative expenditures, and current period obligations. Current period expenditures reported on the March 2023 and December 2023 reports did not agree to the tracking spreadsheet used to prepare the report. The net unreconciled difference in current period expenditures for these quarters was $732,036. The reason for the difference included that OMB's own SLFRF expenditures were not reported in the proper period. Cumulative expenditures reported by OMB for all three covered periods did not agree to the tracking spreadsheet used to prepare the report. The state's actual cumulative expenditures were not determined since changes or revisions can be reflected in the next Project and Expenditures report. However, cumulative expenditures reported by OMB for the covered period ending June 30, 2024, totaled $686,652,130 while cumulative expenditures reported by agencies and universities on SEFAs for the same period totaled $670,946,688. The basis of accounting used to prepare the SEFA varies amongst the agencies and universities; however, the state's cumulative expenditures are expected to reconcile to the state's SLFRF allocation in its final Project and Expenditure Report. Current period obligations reported by OMB for the covered period ending June 30, 2024, totaled $93,696,726, which should have been $0. This error did not impact the cumulative obligation amount since OMB previously reported the state's SLFRF allotment was 100% obligated in the cumulative obligation amount for the covered period ending December 31, 2023. CRITERIA According to Coronavirus State and Local Fiscal Recovery Funds Compliance and Reporting Guidance, states are required to submit quarterly Project and Expenditure Reports. The 2023 and 2024 Compliance Supplements indicate the following line items are key line items: current period obligation, cumulative obligation, current period expenditure, and cumulative expenditure are key line items. In addition, report corrections cannot be made after the reporting deadline unless prompted by Treasury staff. Any changes or revisions will need to be reflected in the next Project and Expenditure report. 2 CFR 200.502 states that the determination of when a federal award is expended must be based on when the activity related to the award occurs. In general, the activity pertains to events that require the nonfederal entity to comply with federal statutes, regulations, and the terms and conditions of federal awards. 2 CFR 200.303(a) states that non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. CAUSE OMB manages State and Local Fiscal Recovery Funds centrally and developed a process to reimburse agencies for their eligible expenditures once expenditures are incurred and agencies requested reimbursement. As a result, reimbursement from the state’s allocation of SLFRF moneys always occurs after the agency expenditure. Funds were included in the federal report for the period in which reimbursement to the agency occurred. In some cases, this resulted in the agency expenditure occurring in a period prior to the period covered under the quarterly SLFRF report. In addition, OMB's reporting process did not identify its own SLFRF expenditures in a timely manner. Lastly, OMB did not consistently utilize its tracking spreadsheet for reporting certain key line items. EFFECT State and Local Fiscal Recovery Funds (SLFRF) data reported to the U.S. Department of Treasury in quarterly Project and Expenditures Reports was inaccurate. CONTEXT In March 2021, the Federal Department of Treasury obligated funds to all 50 states under the State Local and Fiscal Recovery Fund to help states mitigate negative economic impacts caused by the COVID-19 pandemic. In November 2021, the special session of the 67th legislature obligated use of the majority of the funds to various agencies across the state. As the state was able to show that the revenue lost in years 2020 and 2021 exceeded the amount of the obligation from the Department of Treasury, the state was able to claim use of these funds under revenue replacement which allowed the state to utilize them for 'government operations' in addition to other specific uses and also allowing the state to report use of these funds under a single 'revenue replacement' project. The agencies began using the funds for purposes after they were obligated by the state legislature and began recording expenditures against the grant throughout our audit period. When these funds were initially disbursed to the state in March 2021, the funds were received by OMB and OMB then transferred reimbursement to agencies on request. The remainder of the funds were obligated by the state legislature during the 68th Legislative Assembly, which included any turnback funds obligated in previous legislation. North Dakota's project description on the reports was consistent and based on legislative appropriation. As reported, "Due to its extraordinary revenue loss during the pandemic, North Dakota’s entire SLFRF allocation is dedicated to project expenditure category group 6 – Revenue Replacement. Consequently, all expenditures will fall under project expenditure category 6.1 – Provision of Government Services. Government services, as defined by the North Dakota legislature, includes economic development and workforce development initiatives, infrastructure and deferred maintenance initiatives, state service delivery and information technology improvements, and healthcare and emergency response initiatives." Cumulative expenditures reported by OMB for the covered period ending June 30, 2024, totaled $686,652,130. Cumulative expenditures reported by agencies and universities on SEFAs for the same period totaled $670,946,688; however, the basis of accounting used to prepare the SEFA varies amongst the agencies and universities. The state's cumulative expenditures are expected to reconcile to the state's SLFRF allocation in its final Project and Expenditure Report. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Finding 2022-035 was reported in the immediate prior year. RECOMMENDATION We recommend the Office of Management and Budget ensure quarterly Project and Expenditure Reports accurately report the State's SLFRF obligations and expenditures to the Department of Treasury. OFFICE OF MANAGEMENT AND BUDGET RESPONSE The Office of Management agrees with this finding, but will continue federal reporting based on the timing of reimbursement of expenditures to other state agencies for the duration of the SLFRF reporting period. OMB will ensure all expenditures of SFLRF funding are accurately included in the reports based on the period of reimbursement. Because OMB is responsible for the state reporting under this program, it is necessary to maintain some level of control over these funds. Consequently, OMB manages the funds centrally and developed a process to reimburse agencies for their eligible expenditures once expenditures were incurred and agencies requested reimbursement. As a result, reimbursement from the state’s allocation of SLFRF moneys always occurs after the agency expenditure. Funds are included in the Federal report for the period in which reimbursement from the SLFRF occurs. In some cases, this results in the agency expenditure occurring in a period prior to the period covered under the quarterly SLFRF report in which the reimbursement is reported. To better track OMB expenditures of SLFRF moneys, which is a separate process from the reimbursement of other agencies, OMB will run specific expense reports for OMB agency expenditures to ensure all SLFRF expenses are reported in the proper period. See “Management’s Response and Corrective Action” section of this report. AUDITOR’S CONCLUDING COMMENTS While the Office of Management and Budget agrees with the finding, continuing Federal reporting based on the timing of reimbursed expenditures will likely cause further inaccurate SLFRF reporting. In addition, amounts transferred to agencies are not confirmed to not exceed incurred expenditures to ensure a reimbursement process is in place.