Reference Number 2024-005 – Incomplete Schedule of Expenditures of Federal Awards Evaluation of Finding Material Weakness and Noncompliance – Various Federal Programs Criteria According to the Government Auditing Standards (Yellow Book) and the Uniform Guidance, 2 CFR Part 200, Subpart F—Audit Requirements, sections 200.508 and 200.510, entities receiving federal awards must prepare and submit a complete and accurate Schedule of Expenditures of Federal Awards (SEFA) as part of their annual financial reporting. This schedule is crucial for auditors to determine major programs and conduct the necessary audits in compliance with federal regulations. Condition The City failed to provide a complete SEFA for the fiscal year, leading to inaccuracies pertaining to the ARPA program. This omission resulted in a direct impact on the determination of major programs. Cause The incomplete SEFA was caused by a lack of oversight and insufficient internal controls within the City's financial management department. Effect or Potential Effect The failure to provide a complete SEFA has significant implications, including: • Inaccurate determination of major programs, which can affect the scope and quality of the audit process. • Increased risk of non-compliance with federal regulations, potentially leading to financial penalties and loss of federal funding. Context The City did not submit a complete SEFA for the year ended June 30, 2024, as required by federal guidelines. This incomplete reporting could compromise transparency, affect audit procedures, and hinder compliance with federal regulations. Repeat Finding Yes, in relation to reconciliation of grant activity. Recommendation To address this material weakness, the following actions are recommended: • Develop detailed procedures and timelines: Establish and enforce comprehensive procedures and timelines for the preparation and submission of the SEFA to ensure completeness and accuracy. • Enhance staffing and resources: Allocate adequate staffing and resources to the financial management department to support the accurate compilation and timely submission of the SEFA. • Provide comprehensive training: Offer training to financial management staff on the requirements and importance of the SEFA, including techniques for ensuring its accuracy and completeness.. • Regularly audit the SEFA preparation process: Conduct regular audits of the SEFA preparation process to ensure compliance with established policies and procedures and address any deficiencies promptly. This should be completed monthly and at a minimum quarterly. By implementing these recommendations, the City can strengthen its internal controls, improve the accuracy of its financial reporting, and ensure compliance with Government Auditing Standards and other regulatory requirements. Management Response Management agrees with the finding and recommendations. The City will begin to implement policies and procedures to assist with monthly reconciliations and review processes to mitigate these errors in the future. Reference Number 2024-005 – Incomplete Schedule of Expenditures of Federal Awards Material Weakness and Noncompliance Assistance Listing Number: All Federal Programs reported on the SEFA Criteria Refer to finding 2024-005 in section II above. Condition Refer to finding 2024-005 in section II above. Cause of Condition Refer to finding 2024-005 in section II above. Effect or Potential Effect of Condition Refer to finding 2024-005 in section II above. Questioned costs None. Context Refer to finding 2024-005 in section II above. Repeat Finding Refer to finding 2024-005 in section II above. Recommendation Refer to finding 2024-005 in section II above. Management Response Refer to finding 2024-005 in section II above.
Reference Number 2024-005 – Incomplete Schedule of Expenditures of Federal Awards Evaluation of Finding Material Weakness and Noncompliance – Various Federal Programs Criteria According to the Government Auditing Standards (Yellow Book) and the Uniform Guidance, 2 CFR Part 200, Subpart F—Audit Requirements, sections 200.508 and 200.510, entities receiving federal awards must prepare and submit a complete and accurate Schedule of Expenditures of Federal Awards (SEFA) as part of their annual financial reporting. This schedule is crucial for auditors to determine major programs and conduct the necessary audits in compliance with federal regulations. Condition The City failed to provide a complete SEFA for the fiscal year, leading to inaccuracies pertaining to the ARPA program. This omission resulted in a direct impact on the determination of major programs. Cause The incomplete SEFA was caused by a lack of oversight and insufficient internal controls within the City's financial management department. Effect or Potential Effect The failure to provide a complete SEFA has significant implications, including: • Inaccurate determination of major programs, which can affect the scope and quality of the audit process. • Increased risk of non-compliance with federal regulations, potentially leading to financial penalties and loss of federal funding. Context The City did not submit a complete SEFA for the year ended June 30, 2024, as required by federal guidelines. This incomplete reporting could compromise transparency, affect audit procedures, and hinder compliance with federal regulations. Repeat Finding Yes, in relation to reconciliation of grant activity. Recommendation To address this material weakness, the following actions are recommended: • Develop detailed procedures and timelines: Establish and enforce comprehensive procedures and timelines for the preparation and submission of the SEFA to ensure completeness and accuracy. • Enhance staffing and resources: Allocate adequate staffing and resources to the financial management department to support the accurate compilation and timely submission of the SEFA. • Provide comprehensive training: Offer training to financial management staff on the requirements and importance of the SEFA, including techniques for ensuring its accuracy and completeness.. • Regularly audit the SEFA preparation process: Conduct regular audits of the SEFA preparation process to ensure compliance with established policies and procedures and address any deficiencies promptly. This should be completed monthly and at a minimum quarterly. By implementing these recommendations, the City can strengthen its internal controls, improve the accuracy of its financial reporting, and ensure compliance with Government Auditing Standards and other regulatory requirements. Management Response Management agrees with the finding and recommendations. The City will begin to implement policies and procedures to assist with monthly reconciliations and review processes to mitigate these errors in the future. Reference Number 2024-005 – Incomplete Schedule of Expenditures of Federal Awards Material Weakness and Noncompliance Assistance Listing Number: All Federal Programs reported on the SEFA Criteria Refer to finding 2024-005 in section II above. Condition Refer to finding 2024-005 in section II above. Cause of Condition Refer to finding 2024-005 in section II above. Effect or Potential Effect of Condition Refer to finding 2024-005 in section II above. Questioned costs None. Context Refer to finding 2024-005 in section II above. Repeat Finding Refer to finding 2024-005 in section II above. Recommendation Refer to finding 2024-005 in section II above. Management Response Refer to finding 2024-005 in section II above.
Reference Number 2024-005 – Incomplete Schedule of Expenditures of Federal Awards Evaluation of Finding Material Weakness and Noncompliance – Various Federal Programs Criteria According to the Government Auditing Standards (Yellow Book) and the Uniform Guidance, 2 CFR Part 200, Subpart F—Audit Requirements, sections 200.508 and 200.510, entities receiving federal awards must prepare and submit a complete and accurate Schedule of Expenditures of Federal Awards (SEFA) as part of their annual financial reporting. This schedule is crucial for auditors to determine major programs and conduct the necessary audits in compliance with federal regulations. Condition The City failed to provide a complete SEFA for the fiscal year, leading to inaccuracies pertaining to the ARPA program. This omission resulted in a direct impact on the determination of major programs. Cause The incomplete SEFA was caused by a lack of oversight and insufficient internal controls within the City's financial management department. Effect or Potential Effect The failure to provide a complete SEFA has significant implications, including: • Inaccurate determination of major programs, which can affect the scope and quality of the audit process. • Increased risk of non-compliance with federal regulations, potentially leading to financial penalties and loss of federal funding. Context The City did not submit a complete SEFA for the year ended June 30, 2024, as required by federal guidelines. This incomplete reporting could compromise transparency, affect audit procedures, and hinder compliance with federal regulations. Repeat Finding Yes, in relation to reconciliation of grant activity. Recommendation To address this material weakness, the following actions are recommended: • Develop detailed procedures and timelines: Establish and enforce comprehensive procedures and timelines for the preparation and submission of the SEFA to ensure completeness and accuracy. • Enhance staffing and resources: Allocate adequate staffing and resources to the financial management department to support the accurate compilation and timely submission of the SEFA. • Provide comprehensive training: Offer training to financial management staff on the requirements and importance of the SEFA, including techniques for ensuring its accuracy and completeness.. • Regularly audit the SEFA preparation process: Conduct regular audits of the SEFA preparation process to ensure compliance with established policies and procedures and address any deficiencies promptly. This should be completed monthly and at a minimum quarterly. By implementing these recommendations, the City can strengthen its internal controls, improve the accuracy of its financial reporting, and ensure compliance with Government Auditing Standards and other regulatory requirements. Management Response Management agrees with the finding and recommendations. The City will begin to implement policies and procedures to assist with monthly reconciliations and review processes to mitigate these errors in the future. Reference Number 2024-005 – Incomplete Schedule of Expenditures of Federal Awards Material Weakness and Noncompliance Assistance Listing Number: All Federal Programs reported on the SEFA Criteria Refer to finding 2024-005 in section II above. Condition Refer to finding 2024-005 in section II above. Cause of Condition Refer to finding 2024-005 in section II above. Effect or Potential Effect of Condition Refer to finding 2024-005 in section II above. Questioned costs None. Context Refer to finding 2024-005 in section II above. Repeat Finding Refer to finding 2024-005 in section II above. Recommendation Refer to finding 2024-005 in section II above. Management Response Refer to finding 2024-005 in section II above.
Reference Number 2024-005 – Incomplete Schedule of Expenditures of Federal Awards Evaluation of Finding Material Weakness and Noncompliance – Various Federal Programs Criteria According to the Government Auditing Standards (Yellow Book) and the Uniform Guidance, 2 CFR Part 200, Subpart F—Audit Requirements, sections 200.508 and 200.510, entities receiving federal awards must prepare and submit a complete and accurate Schedule of Expenditures of Federal Awards (SEFA) as part of their annual financial reporting. This schedule is crucial for auditors to determine major programs and conduct the necessary audits in compliance with federal regulations. Condition The City failed to provide a complete SEFA for the fiscal year, leading to inaccuracies pertaining to the ARPA program. This omission resulted in a direct impact on the determination of major programs. Cause The incomplete SEFA was caused by a lack of oversight and insufficient internal controls within the City's financial management department. Effect or Potential Effect The failure to provide a complete SEFA has significant implications, including: • Inaccurate determination of major programs, which can affect the scope and quality of the audit process. • Increased risk of non-compliance with federal regulations, potentially leading to financial penalties and loss of federal funding. Context The City did not submit a complete SEFA for the year ended June 30, 2024, as required by federal guidelines. This incomplete reporting could compromise transparency, affect audit procedures, and hinder compliance with federal regulations. Repeat Finding Yes, in relation to reconciliation of grant activity. Recommendation To address this material weakness, the following actions are recommended: • Develop detailed procedures and timelines: Establish and enforce comprehensive procedures and timelines for the preparation and submission of the SEFA to ensure completeness and accuracy. • Enhance staffing and resources: Allocate adequate staffing and resources to the financial management department to support the accurate compilation and timely submission of the SEFA. • Provide comprehensive training: Offer training to financial management staff on the requirements and importance of the SEFA, including techniques for ensuring its accuracy and completeness.. • Regularly audit the SEFA preparation process: Conduct regular audits of the SEFA preparation process to ensure compliance with established policies and procedures and address any deficiencies promptly. This should be completed monthly and at a minimum quarterly. By implementing these recommendations, the City can strengthen its internal controls, improve the accuracy of its financial reporting, and ensure compliance with Government Auditing Standards and other regulatory requirements. Management Response Management agrees with the finding and recommendations. The City will begin to implement policies and procedures to assist with monthly reconciliations and review processes to mitigate these errors in the future. Reference Number 2024-005 – Incomplete Schedule of Expenditures of Federal Awards Material Weakness and Noncompliance Assistance Listing Number: All Federal Programs reported on the SEFA Criteria Refer to finding 2024-005 in section II above. Condition Refer to finding 2024-005 in section II above. Cause of Condition Refer to finding 2024-005 in section II above. Effect or Potential Effect of Condition Refer to finding 2024-005 in section II above. Questioned costs None. Context Refer to finding 2024-005 in section II above. Repeat Finding Refer to finding 2024-005 in section II above. Recommendation Refer to finding 2024-005 in section II above. Management Response Refer to finding 2024-005 in section II above.
Finding 2024-004 Accounting for Grants, Schedule of Expenditures of Federal Awards, and Fiscal Man-agement (Material Weakness) Assistance Listing Number and Title: 84.041 Impact Aid Name of Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 84.010 Title I Name of Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 10.553 and 10.555 National School Lunch Breakfast and Lunch Name of Federal Agency: U.S. Department of Agriculture Criteria: CFR Part 200.508, CFR Part 200.510, Auditee Responsibilities state that the auditee must prepare the Sched-ule of Expenditures of Federal Awards, which must list individual Federal awards by Federal Agency, including the to-tal Federal awards expended, name of the pass-through entity, CFDA number, and total amount provided to subrecipi-ents. The information contained in the Schedule of Expenditures of Federal Awards should be derived from and relate directly to the underlying accounting and other records used to prepare the financial statements. Condition: The Schedule of Expenditures of Federal Awards (SEFA) was presented for audit with values that were not reconciled with the general ledger, and contained inaccuracies, including: • Overclaimed revenues for Title I • Inability to provide sufficient documentation of Impact Aid revenues and specific Impact Aid program infor-mation • Incorrect reporting of state and federal revenues for National School Lunch Program. Cause: The District does not have effective internal control over the preparation of the Schedule of Expenditures of Federal Awards. The district did not reconcile the expenditures reported on the SEFA with the amounts reported on the district's general ledger. Effect or Potential Effect: Potential understatement or overstatement of expenditures could exist in the Schedule of Expenditures of Federal Awards and not be detected and corrected. Because the SEFA was completed incorrectly, and not reconciled to the general ledger, the financial statements were materially misstated prior to the auditor's adjust-ments. Questioned Cost: No Context: Lack of adequate controls over the Schedule of Expenditures of Federal Awards and related accounting re-sulted in the following: SEFA was originally presented for auditors with incorrect information, and not reconciled to the general ledger Repeat of a Prior-Year Finding: No Recommendation: We recommend that the District establish policies and procedures to ensure that all Federal awards are identified and reported accurately on future SEFAs. Internal controls should be designed to prevent, detect, or cor-rect errors in a timely manner by performing periodic reconciliations of the SEFA information to the general ledger throughout the fiscal year. The District should provide appropriate training to staff who are assigned to prepare and re-view the SEFA. District’s Response: The District acknowledges the deficiencies. Corrective Action Plan: The District will establish policies and procedures to ensure that all Federal awards are identi-fied and reported accurately on future SEFAs. Planned Implementation Date: August 1, 2025 Responsible Person: District Business Manager Section IV—Summary Schedule of Prior Audit Findings There were no findings for the fiscal year ended June 30, 2023.
Finding 2024-004 Accounting for Grants, Schedule of Expenditures of Federal Awards, and Fiscal Man-agement (Material Weakness) Assistance Listing Number and Title: 84.041 Impact Aid Name of Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 84.010 Title I Name of Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 10.553 and 10.555 National School Lunch Breakfast and Lunch Name of Federal Agency: U.S. Department of Agriculture Criteria: CFR Part 200.508, CFR Part 200.510, Auditee Responsibilities state that the auditee must prepare the Sched-ule of Expenditures of Federal Awards, which must list individual Federal awards by Federal Agency, including the to-tal Federal awards expended, name of the pass-through entity, CFDA number, and total amount provided to subrecipi-ents. The information contained in the Schedule of Expenditures of Federal Awards should be derived from and relate directly to the underlying accounting and other records used to prepare the financial statements. Condition: The Schedule of Expenditures of Federal Awards (SEFA) was presented for audit with values that were not reconciled with the general ledger, and contained inaccuracies, including: • Overclaimed revenues for Title I • Inability to provide sufficient documentation of Impact Aid revenues and specific Impact Aid program infor-mation • Incorrect reporting of state and federal revenues for National School Lunch Program. Cause: The District does not have effective internal control over the preparation of the Schedule of Expenditures of Federal Awards. The district did not reconcile the expenditures reported on the SEFA with the amounts reported on the district's general ledger. Effect or Potential Effect: Potential understatement or overstatement of expenditures could exist in the Schedule of Expenditures of Federal Awards and not be detected and corrected. Because the SEFA was completed incorrectly, and not reconciled to the general ledger, the financial statements were materially misstated prior to the auditor's adjust-ments. Questioned Cost: No Context: Lack of adequate controls over the Schedule of Expenditures of Federal Awards and related accounting re-sulted in the following: SEFA was originally presented for auditors with incorrect information, and not reconciled to the general ledger Repeat of a Prior-Year Finding: No Recommendation: We recommend that the District establish policies and procedures to ensure that all Federal awards are identified and reported accurately on future SEFAs. Internal controls should be designed to prevent, detect, or cor-rect errors in a timely manner by performing periodic reconciliations of the SEFA information to the general ledger throughout the fiscal year. The District should provide appropriate training to staff who are assigned to prepare and re-view the SEFA. District’s Response: The District acknowledges the deficiencies. Corrective Action Plan: The District will establish policies and procedures to ensure that all Federal awards are identi-fied and reported accurately on future SEFAs. Planned Implementation Date: August 1, 2025 Responsible Person: District Business Manager Section IV—Summary Schedule of Prior Audit Findings There were no findings for the fiscal year ended June 30, 2023.
Finding 2024-004 Accounting for Grants, Schedule of Expenditures of Federal Awards, and Fiscal Man-agement (Material Weakness) Assistance Listing Number and Title: 84.041 Impact Aid Name of Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 84.010 Title I Name of Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 10.553 and 10.555 National School Lunch Breakfast and Lunch Name of Federal Agency: U.S. Department of Agriculture Criteria: CFR Part 200.508, CFR Part 200.510, Auditee Responsibilities state that the auditee must prepare the Sched-ule of Expenditures of Federal Awards, which must list individual Federal awards by Federal Agency, including the to-tal Federal awards expended, name of the pass-through entity, CFDA number, and total amount provided to subrecipi-ents. The information contained in the Schedule of Expenditures of Federal Awards should be derived from and relate directly to the underlying accounting and other records used to prepare the financial statements. Condition: The Schedule of Expenditures of Federal Awards (SEFA) was presented for audit with values that were not reconciled with the general ledger, and contained inaccuracies, including: • Overclaimed revenues for Title I • Inability to provide sufficient documentation of Impact Aid revenues and specific Impact Aid program infor-mation • Incorrect reporting of state and federal revenues for National School Lunch Program. Cause: The District does not have effective internal control over the preparation of the Schedule of Expenditures of Federal Awards. The district did not reconcile the expenditures reported on the SEFA with the amounts reported on the district's general ledger. Effect or Potential Effect: Potential understatement or overstatement of expenditures could exist in the Schedule of Expenditures of Federal Awards and not be detected and corrected. Because the SEFA was completed incorrectly, and not reconciled to the general ledger, the financial statements were materially misstated prior to the auditor's adjust-ments. Questioned Cost: No Context: Lack of adequate controls over the Schedule of Expenditures of Federal Awards and related accounting re-sulted in the following: SEFA was originally presented for auditors with incorrect information, and not reconciled to the general ledger Repeat of a Prior-Year Finding: No Recommendation: We recommend that the District establish policies and procedures to ensure that all Federal awards are identified and reported accurately on future SEFAs. Internal controls should be designed to prevent, detect, or cor-rect errors in a timely manner by performing periodic reconciliations of the SEFA information to the general ledger throughout the fiscal year. The District should provide appropriate training to staff who are assigned to prepare and re-view the SEFA. District’s Response: The District acknowledges the deficiencies. Corrective Action Plan: The District will establish policies and procedures to ensure that all Federal awards are identi-fied and reported accurately on future SEFAs. Planned Implementation Date: August 1, 2025 Responsible Person: District Business Manager Section IV—Summary Schedule of Prior Audit Findings There were no findings for the fiscal year ended June 30, 2023.
Finding 2024-004 Accounting for Grants, Schedule of Expenditures of Federal Awards, and Fiscal Man-agement (Material Weakness) Assistance Listing Number and Title: 84.041 Impact Aid Name of Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 84.010 Title I Name of Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 10.553 and 10.555 National School Lunch Breakfast and Lunch Name of Federal Agency: U.S. Department of Agriculture Criteria: CFR Part 200.508, CFR Part 200.510, Auditee Responsibilities state that the auditee must prepare the Sched-ule of Expenditures of Federal Awards, which must list individual Federal awards by Federal Agency, including the to-tal Federal awards expended, name of the pass-through entity, CFDA number, and total amount provided to subrecipi-ents. The information contained in the Schedule of Expenditures of Federal Awards should be derived from and relate directly to the underlying accounting and other records used to prepare the financial statements. Condition: The Schedule of Expenditures of Federal Awards (SEFA) was presented for audit with values that were not reconciled with the general ledger, and contained inaccuracies, including: • Overclaimed revenues for Title I • Inability to provide sufficient documentation of Impact Aid revenues and specific Impact Aid program infor-mation • Incorrect reporting of state and federal revenues for National School Lunch Program. Cause: The District does not have effective internal control over the preparation of the Schedule of Expenditures of Federal Awards. The district did not reconcile the expenditures reported on the SEFA with the amounts reported on the district's general ledger. Effect or Potential Effect: Potential understatement or overstatement of expenditures could exist in the Schedule of Expenditures of Federal Awards and not be detected and corrected. Because the SEFA was completed incorrectly, and not reconciled to the general ledger, the financial statements were materially misstated prior to the auditor's adjust-ments. Questioned Cost: No Context: Lack of adequate controls over the Schedule of Expenditures of Federal Awards and related accounting re-sulted in the following: SEFA was originally presented for auditors with incorrect information, and not reconciled to the general ledger Repeat of a Prior-Year Finding: No Recommendation: We recommend that the District establish policies and procedures to ensure that all Federal awards are identified and reported accurately on future SEFAs. Internal controls should be designed to prevent, detect, or cor-rect errors in a timely manner by performing periodic reconciliations of the SEFA information to the general ledger throughout the fiscal year. The District should provide appropriate training to staff who are assigned to prepare and re-view the SEFA. District’s Response: The District acknowledges the deficiencies. Corrective Action Plan: The District will establish policies and procedures to ensure that all Federal awards are identi-fied and reported accurately on future SEFAs. Planned Implementation Date: August 1, 2025 Responsible Person: District Business Manager Section IV—Summary Schedule of Prior Audit Findings There were no findings for the fiscal year ended June 30, 2023.
Finding 2024-004 Accounting for Grants, Schedule of Expenditures of Federal Awards, and Fiscal Man-agement (Material Weakness) Assistance Listing Number and Title: 84.041 Impact Aid Name of Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 84.010 Title I Name of Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 10.553 and 10.555 National School Lunch Breakfast and Lunch Name of Federal Agency: U.S. Department of Agriculture Criteria: CFR Part 200.508, CFR Part 200.510, Auditee Responsibilities state that the auditee must prepare the Sched-ule of Expenditures of Federal Awards, which must list individual Federal awards by Federal Agency, including the to-tal Federal awards expended, name of the pass-through entity, CFDA number, and total amount provided to subrecipi-ents. The information contained in the Schedule of Expenditures of Federal Awards should be derived from and relate directly to the underlying accounting and other records used to prepare the financial statements. Condition: The Schedule of Expenditures of Federal Awards (SEFA) was presented for audit with values that were not reconciled with the general ledger, and contained inaccuracies, including: • Overclaimed revenues for Title I • Inability to provide sufficient documentation of Impact Aid revenues and specific Impact Aid program infor-mation • Incorrect reporting of state and federal revenues for National School Lunch Program. Cause: The District does not have effective internal control over the preparation of the Schedule of Expenditures of Federal Awards. The district did not reconcile the expenditures reported on the SEFA with the amounts reported on the district's general ledger. Effect or Potential Effect: Potential understatement or overstatement of expenditures could exist in the Schedule of Expenditures of Federal Awards and not be detected and corrected. Because the SEFA was completed incorrectly, and not reconciled to the general ledger, the financial statements were materially misstated prior to the auditor's adjust-ments. Questioned Cost: No Context: Lack of adequate controls over the Schedule of Expenditures of Federal Awards and related accounting re-sulted in the following: SEFA was originally presented for auditors with incorrect information, and not reconciled to the general ledger Repeat of a Prior-Year Finding: No Recommendation: We recommend that the District establish policies and procedures to ensure that all Federal awards are identified and reported accurately on future SEFAs. Internal controls should be designed to prevent, detect, or cor-rect errors in a timely manner by performing periodic reconciliations of the SEFA information to the general ledger throughout the fiscal year. The District should provide appropriate training to staff who are assigned to prepare and re-view the SEFA. District’s Response: The District acknowledges the deficiencies. Corrective Action Plan: The District will establish policies and procedures to ensure that all Federal awards are identi-fied and reported accurately on future SEFAs. Planned Implementation Date: August 1, 2025 Responsible Person: District Business Manager Section IV—Summary Schedule of Prior Audit Findings There were no findings for the fiscal year ended June 30, 2023.
Finding 2024-004 Accounting for Grants, Schedule of Expenditures of Federal Awards, and Fiscal Man-agement (Material Weakness) Assistance Listing Number and Title: 84.041 Impact Aid Name of Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 84.010 Title I Name of Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 10.553 and 10.555 National School Lunch Breakfast and Lunch Name of Federal Agency: U.S. Department of Agriculture Criteria: CFR Part 200.508, CFR Part 200.510, Auditee Responsibilities state that the auditee must prepare the Sched-ule of Expenditures of Federal Awards, which must list individual Federal awards by Federal Agency, including the to-tal Federal awards expended, name of the pass-through entity, CFDA number, and total amount provided to subrecipi-ents. The information contained in the Schedule of Expenditures of Federal Awards should be derived from and relate directly to the underlying accounting and other records used to prepare the financial statements. Condition: The Schedule of Expenditures of Federal Awards (SEFA) was presented for audit with values that were not reconciled with the general ledger, and contained inaccuracies, including: • Overclaimed revenues for Title I • Inability to provide sufficient documentation of Impact Aid revenues and specific Impact Aid program infor-mation • Incorrect reporting of state and federal revenues for National School Lunch Program. Cause: The District does not have effective internal control over the preparation of the Schedule of Expenditures of Federal Awards. The district did not reconcile the expenditures reported on the SEFA with the amounts reported on the district's general ledger. Effect or Potential Effect: Potential understatement or overstatement of expenditures could exist in the Schedule of Expenditures of Federal Awards and not be detected and corrected. Because the SEFA was completed incorrectly, and not reconciled to the general ledger, the financial statements were materially misstated prior to the auditor's adjust-ments. Questioned Cost: No Context: Lack of adequate controls over the Schedule of Expenditures of Federal Awards and related accounting re-sulted in the following: SEFA was originally presented for auditors with incorrect information, and not reconciled to the general ledger Repeat of a Prior-Year Finding: No Recommendation: We recommend that the District establish policies and procedures to ensure that all Federal awards are identified and reported accurately on future SEFAs. Internal controls should be designed to prevent, detect, or cor-rect errors in a timely manner by performing periodic reconciliations of the SEFA information to the general ledger throughout the fiscal year. The District should provide appropriate training to staff who are assigned to prepare and re-view the SEFA. District’s Response: The District acknowledges the deficiencies. Corrective Action Plan: The District will establish policies and procedures to ensure that all Federal awards are identi-fied and reported accurately on future SEFAs. Planned Implementation Date: August 1, 2025 Responsible Person: District Business Manager Section IV—Summary Schedule of Prior Audit Findings There were no findings for the fiscal year ended June 30, 2023.
Finding 2024-004 Accounting for Grants, Schedule of Expenditures of Federal Awards, and Fiscal Man-agement (Material Weakness) Assistance Listing Number and Title: 84.041 Impact Aid Name of Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 84.010 Title I Name of Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 10.553 and 10.555 National School Lunch Breakfast and Lunch Name of Federal Agency: U.S. Department of Agriculture Criteria: CFR Part 200.508, CFR Part 200.510, Auditee Responsibilities state that the auditee must prepare the Sched-ule of Expenditures of Federal Awards, which must list individual Federal awards by Federal Agency, including the to-tal Federal awards expended, name of the pass-through entity, CFDA number, and total amount provided to subrecipi-ents. The information contained in the Schedule of Expenditures of Federal Awards should be derived from and relate directly to the underlying accounting and other records used to prepare the financial statements. Condition: The Schedule of Expenditures of Federal Awards (SEFA) was presented for audit with values that were not reconciled with the general ledger, and contained inaccuracies, including: • Overclaimed revenues for Title I • Inability to provide sufficient documentation of Impact Aid revenues and specific Impact Aid program infor-mation • Incorrect reporting of state and federal revenues for National School Lunch Program. Cause: The District does not have effective internal control over the preparation of the Schedule of Expenditures of Federal Awards. The district did not reconcile the expenditures reported on the SEFA with the amounts reported on the district's general ledger. Effect or Potential Effect: Potential understatement or overstatement of expenditures could exist in the Schedule of Expenditures of Federal Awards and not be detected and corrected. Because the SEFA was completed incorrectly, and not reconciled to the general ledger, the financial statements were materially misstated prior to the auditor's adjust-ments. Questioned Cost: No Context: Lack of adequate controls over the Schedule of Expenditures of Federal Awards and related accounting re-sulted in the following: SEFA was originally presented for auditors with incorrect information, and not reconciled to the general ledger Repeat of a Prior-Year Finding: No Recommendation: We recommend that the District establish policies and procedures to ensure that all Federal awards are identified and reported accurately on future SEFAs. Internal controls should be designed to prevent, detect, or cor-rect errors in a timely manner by performing periodic reconciliations of the SEFA information to the general ledger throughout the fiscal year. The District should provide appropriate training to staff who are assigned to prepare and re-view the SEFA. District’s Response: The District acknowledges the deficiencies. Corrective Action Plan: The District will establish policies and procedures to ensure that all Federal awards are identi-fied and reported accurately on future SEFAs. Planned Implementation Date: August 1, 2025 Responsible Person: District Business Manager Section IV—Summary Schedule of Prior Audit Findings There were no findings for the fiscal year ended June 30, 2023.
Finding 2024-003 - Schedule of Expenditures of Federal Awards (Material Weakness) CFDA Title and Number 84.425 Education Stabilization Fund Name of Federal Agency: U.S. Department of Education CFDA Title and Number 84.010 Grants to Local Education Agencies (Title I) Name of Federal Agency: U.S. Department of Education Compliance/Internal Control over Compliance: Auditee Responsibilities Criteria: CFR Part 200.508, CFR Part 200.510, Auditee Responsibilities state that the auditee must prepare the Schedule of Expenditures of Federal Awards, which must list individual Federal awards by Federal Agency, including the total Federal awards expended, name of the pass-through entity, CFDA number, and total amount provided to subrecipients. The information contained in the Schedule of Expenditures of Federal Awards should be derived from and relate directly to the underlying accounting and other records used to prepare the financial statements. Condition: The Schedule of Expenditures of Federal Awards (SEFA) was presented for audit on an untimely basis, and with values that were not reconciled with the general ledger. Cause: The District staff had insufficient training or support to prepare the SEFA and ensure that it was reconciled with general ledger amounts. District management did not have monitoring policies to recognize and correct the deficiency. Effect or Potential Effect: Errors in recording and reporting of revenues and expenditures of federal awards may not be detected and/or corrected. Because the Auditee’s SEFA that was presented for audit was completed incorrectly, and not reconciled to the general ledger, the SEFA was materially misstated, prior to auditor's correction recommendations. Questioned Cost: No Context: Lack of adequate controls over the Schedule of Expenditures of Federal Awards and related accounting resulted in the following: SEFA was originally presented for auditors with incorrect information. SEFA was not presented for auditors on a timely basis. No reconciliation between federal expenditures reported on the GL and the SEFA was presented. Repeat of a Prior-Year Finding: No Recommendation: We recommend that the District establish policies and procedures to ensure that all Federal awards are identified and reported accurately on future SEFAs. Internal controls should be designed to prevent, detect, or correct errors in a timely manner by performing periodic reconciliations of the SEFA information to the general ledger throughout the fiscal year. The District should provide appropriate training to staff who are assigned to prepare and review the SEFA. District’s Response: The District acknowledges the deficiencies. Corrective Action Plan: The District will establish policies and procedures to ensure that all Federal awards are identified and reported accurately on future SEFA reports. Planned Implementation Date: August 1, 2025 Responsible Person: Director of Business Services, Yamhill County School District No. 8
2023-002 - Deficiency in Internal Controls Over SEFA Preparation and Material Adjustments Finding Type: Material Weakness in Internal Control Over Compliance Programs: Coronavirus State and Local Fiscal Recovery Funds (Assistance Listing Number 21.027) and Capitalization Grants for Clean Water State Revolving Funds (Assistance Listing Number 66.458) Criteria: According to 2 CFR § 200.508(b), the auditee is responsible for preparing appropriate financial statements, including the Schedule of Expenditures of Federal Awards (SEFA). The Uniform Guidance requires that auditees maintain adequate internal controls over financial reporting to ensure that financial statements and the SEFA are accurate, complete, and prepared in accordance with applicable regulations. Condition/Finding: During the course of our federal single audit, it was observed that the Schedule of Expenditures of Federal Awards (“SEFA”) was prepared by the auditor instead of the Township. Although the Township reviewed and accepted the SEFA, the preparation was not independently performed by the Township. Additionally, the auditor proposed and the Township accepted material proposed audit adjusting journal entries that impacted the federal awards reported on the SEFA. Cause: The Township lacks sufficient staff with the necessary skills and knowledge to independently prepare the SEFA. As a result, the Township relies on the auditor to compile this schedule and to propose material audit adjustments. The Township has limited resources, which contributes to this reliance. Effect: Reliance on the auditor to prepare the SEFA and to propose material audit adjustments indicates a deficiency in the Township’s internal controls over financial reporting. This situation increases the risk that the SEFA may not be accurately or completely prepared if the auditor does not perform these tasks. Additionally, this reliance could potentially result in a significant deficiency or material weakness in the Township’s internal control over financial reporting. Questioned Costs: No costs have been questioned as a result of this finding. Repeat Finding: No Recommendation: To correct this finding in the future, we recommend that the Township take the following actions: 1. Staff Training: Provide additional training to current staff on the requirements and preparation of the SEFA to build the necessary skills and knowledge internally. 2. Develop Detailed Procedures: Develop and document detailed procedures and guidelines for preparing the SEFA, including checklists and timelines, to assist staff in the accurate preparation of this schedule. 3. Review and Approval Process: Establish a robust review and approval process where a knowledgeable individual within the organization reviews the SEFA for accuracy and completeness before submission. 4. Improve Internal Controls: Enhance internal controls over financial reporting to ensure that material audit adjustments are minimized and that the financial statements and SEFA are prepared accurately and independently. View of Responsible Officials (Corrective Action): See corrective action plan.
2023-002 - Deficiency in Internal Controls Over SEFA Preparation and Material Adjustments Finding Type: Material Weakness in Internal Control Over Compliance Programs: Coronavirus State and Local Fiscal Recovery Funds (Assistance Listing Number 21.027) and Capitalization Grants for Clean Water State Revolving Funds (Assistance Listing Number 66.458) Criteria: According to 2 CFR § 200.508(b), the auditee is responsible for preparing appropriate financial statements, including the Schedule of Expenditures of Federal Awards (SEFA). The Uniform Guidance requires that auditees maintain adequate internal controls over financial reporting to ensure that financial statements and the SEFA are accurate, complete, and prepared in accordance with applicable regulations. Condition/Finding: During the course of our federal single audit, it was observed that the Schedule of Expenditures of Federal Awards (“SEFA”) was prepared by the auditor instead of the Township. Although the Township reviewed and accepted the SEFA, the preparation was not independently performed by the Township. Additionally, the auditor proposed and the Township accepted material proposed audit adjusting journal entries that impacted the federal awards reported on the SEFA. Cause: The Township lacks sufficient staff with the necessary skills and knowledge to independently prepare the SEFA. As a result, the Township relies on the auditor to compile this schedule and to propose material audit adjustments. The Township has limited resources, which contributes to this reliance. Effect: Reliance on the auditor to prepare the SEFA and to propose material audit adjustments indicates a deficiency in the Township’s internal controls over financial reporting. This situation increases the risk that the SEFA may not be accurately or completely prepared if the auditor does not perform these tasks. Additionally, this reliance could potentially result in a significant deficiency or material weakness in the Township’s internal control over financial reporting. Questioned Costs: No costs have been questioned as a result of this finding. Repeat Finding: No Recommendation: To correct this finding in the future, we recommend that the Township take the following actions: 1. Staff Training: Provide additional training to current staff on the requirements and preparation of the SEFA to build the necessary skills and knowledge internally. 2. Develop Detailed Procedures: Develop and document detailed procedures and guidelines for preparing the SEFA, including checklists and timelines, to assist staff in the accurate preparation of this schedule. 3. Review and Approval Process: Establish a robust review and approval process where a knowledgeable individual within the organization reviews the SEFA for accuracy and completeness before submission. 4. Improve Internal Controls: Enhance internal controls over financial reporting to ensure that material audit adjustments are minimized and that the financial statements and SEFA are prepared accurately and independently. View of Responsible Officials (Corrective Action): See corrective action plan.
2023-002 - Deficiency in Internal Controls Over SEFA Preparation and Material Adjustments Finding Type: Material Weakness in Internal Control Over Compliance Programs: Coronavirus State and Local Fiscal Recovery Funds (Assistance Listing Number 21.027) and Capitalization Grants for Clean Water State Revolving Funds (Assistance Listing Number 66.458) Criteria: According to 2 CFR § 200.508(b), the auditee is responsible for preparing appropriate financial statements, including the Schedule of Expenditures of Federal Awards (SEFA). The Uniform Guidance requires that auditees maintain adequate internal controls over financial reporting to ensure that financial statements and the SEFA are accurate, complete, and prepared in accordance with applicable regulations. Condition/Finding: During the course of our federal single audit, it was observed that the Schedule of Expenditures of Federal Awards (“SEFA”) was prepared by the auditor instead of the Township. Although the Township reviewed and accepted the SEFA, the preparation was not independently performed by the Township. Additionally, the auditor proposed and the Township accepted material proposed audit adjusting journal entries that impacted the federal awards reported on the SEFA. Cause: The Township lacks sufficient staff with the necessary skills and knowledge to independently prepare the SEFA. As a result, the Township relies on the auditor to compile this schedule and to propose material audit adjustments. The Township has limited resources, which contributes to this reliance. Effect: Reliance on the auditor to prepare the SEFA and to propose material audit adjustments indicates a deficiency in the Township’s internal controls over financial reporting. This situation increases the risk that the SEFA may not be accurately or completely prepared if the auditor does not perform these tasks. Additionally, this reliance could potentially result in a significant deficiency or material weakness in the Township’s internal control over financial reporting. Questioned Costs: No costs have been questioned as a result of this finding. Repeat Finding: No Recommendation: To correct this finding in the future, we recommend that the Township take the following actions: 1. Staff Training: Provide additional training to current staff on the requirements and preparation of the SEFA to build the necessary skills and knowledge internally. 2. Develop Detailed Procedures: Develop and document detailed procedures and guidelines for preparing the SEFA, including checklists and timelines, to assist staff in the accurate preparation of this schedule. 3. Review and Approval Process: Establish a robust review and approval process where a knowledgeable individual within the organization reviews the SEFA for accuracy and completeness before submission. 4. Improve Internal Controls: Enhance internal controls over financial reporting to ensure that material audit adjustments are minimized and that the financial statements and SEFA are prepared accurately and independently. View of Responsible Officials (Corrective Action): See corrective action plan.
Finding 2023-001: Preparation of Schedule of Expenditures of Federal Awards (SEFA) Information on the Federal Programs: All Criteria: As noted in 2 CFR 200.508 “Auditee Responsibilities” indicates that the auditee must prepare appropriate financial statements, including the Schedule of Expenditures of Federal Awards (as specifically defined under 2 CFR 200.510 “Financial statements”). Title 2 CFR 200 Section 200.510 “Financial Statements” requires recipients of Federal funds to 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. Additionally, in accordance with CFR 200.303, the non- Federal entity must: establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Accountability Lab experienced difficulty in preparing and ensuring that all Federal expenditures were identified, categorized, and included in the Schedule of Expenditures of Federal Awards. The preparation of Accountability Lab's SEFA required manual adjustments of Federal costs. We noted that the manual adjustments were not completed prior to the start of the audit. We also noted that a certain award was not clearly identified as Federal pass-through funds and therefore not initially included on the SEFA. As a result, several adjustments were posted to the financial statements to ensure Federal receivables, refundable advances and Federal revenue were properly recognized and accurately stated at year-end. Cause: The year-end close process did not provide for the preparation of a complete and accurate schedule of expenditures of Federal awards. Effect: Without periodic training and consistent application of Accountability Lab’s internal policies and procedures, this could potentially result in unreliable and erroneous grant reporting, internal record keeping and decision making. Questioned Costs: None noted. Context: Our audit testwork consisted of substantive procedures over the SEFA. We determined that the issue was systemic in nature. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend Accountability Lab establish internal controls to correctly identify and track all Federal awards received either directly or indirectly.
Finding 2023-001: Preparation of Schedule of Expenditures of Federal Awards (SEFA) Information on the Federal Programs: All Criteria: As noted in 2 CFR 200.508 “Auditee Responsibilities” indicates that the auditee must prepare appropriate financial statements, including the Schedule of Expenditures of Federal Awards (as specifically defined under 2 CFR 200.510 “Financial statements”). Title 2 CFR 200 Section 200.510 “Financial Statements” requires recipients of Federal funds to 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. Additionally, in accordance with CFR 200.303, the non- Federal entity must: establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Accountability Lab experienced difficulty in preparing and ensuring that all Federal expenditures were identified, categorized, and included in the Schedule of Expenditures of Federal Awards. The preparation of Accountability Lab's SEFA required manual adjustments of Federal costs. We noted that the manual adjustments were not completed prior to the start of the audit. We also noted that a certain award was not clearly identified as Federal pass-through funds and therefore not initially included on the SEFA. As a result, several adjustments were posted to the financial statements to ensure Federal receivables, refundable advances and Federal revenue were properly recognized and accurately stated at year-end. Cause: The year-end close process did not provide for the preparation of a complete and accurate schedule of expenditures of Federal awards. Effect: Without periodic training and consistent application of Accountability Lab’s internal policies and procedures, this could potentially result in unreliable and erroneous grant reporting, internal record keeping and decision making. Questioned Costs: None noted. Context: Our audit testwork consisted of substantive procedures over the SEFA. We determined that the issue was systemic in nature. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend Accountability Lab establish internal controls to correctly identify and track all Federal awards received either directly or indirectly.
Finding 2023-001: Preparation of Schedule of Expenditures of Federal Awards (SEFA) Information on the Federal Programs: All Criteria: As noted in 2 CFR 200.508 “Auditee Responsibilities” indicates that the auditee must prepare appropriate financial statements, including the Schedule of Expenditures of Federal Awards (as specifically defined under 2 CFR 200.510 “Financial statements”). Title 2 CFR 200 Section 200.510 “Financial Statements” requires recipients of Federal funds to 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. Additionally, in accordance with CFR 200.303, the non- Federal entity must: establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Accountability Lab experienced difficulty in preparing and ensuring that all Federal expenditures were identified, categorized, and included in the Schedule of Expenditures of Federal Awards. The preparation of Accountability Lab's SEFA required manual adjustments of Federal costs. We noted that the manual adjustments were not completed prior to the start of the audit. We also noted that a certain award was not clearly identified as Federal pass-through funds and therefore not initially included on the SEFA. As a result, several adjustments were posted to the financial statements to ensure Federal receivables, refundable advances and Federal revenue were properly recognized and accurately stated at year-end. Cause: The year-end close process did not provide for the preparation of a complete and accurate schedule of expenditures of Federal awards. Effect: Without periodic training and consistent application of Accountability Lab’s internal policies and procedures, this could potentially result in unreliable and erroneous grant reporting, internal record keeping and decision making. Questioned Costs: None noted. Context: Our audit testwork consisted of substantive procedures over the SEFA. We determined that the issue was systemic in nature. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend Accountability Lab establish internal controls to correctly identify and track all Federal awards received either directly or indirectly.
Finding 2023-001: Preparation of Schedule of Expenditures of Federal Awards (SEFA) Information on the Federal Programs: All Criteria: As noted in 2 CFR 200.508 “Auditee Responsibilities” indicates that the auditee must prepare appropriate financial statements, including the Schedule of Expenditures of Federal Awards (as specifically defined under 2 CFR 200.510 “Financial statements”). Title 2 CFR 200 Section 200.510 “Financial Statements” requires recipients of Federal funds to 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. Additionally, in accordance with CFR 200.303, the non- Federal entity must: establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Accountability Lab experienced difficulty in preparing and ensuring that all Federal expenditures were identified, categorized, and included in the Schedule of Expenditures of Federal Awards. The preparation of Accountability Lab's SEFA required manual adjustments of Federal costs. We noted that the manual adjustments were not completed prior to the start of the audit. We also noted that a certain award was not clearly identified as Federal pass-through funds and therefore not initially included on the SEFA. As a result, several adjustments were posted to the financial statements to ensure Federal receivables, refundable advances and Federal revenue were properly recognized and accurately stated at year-end. Cause: The year-end close process did not provide for the preparation of a complete and accurate schedule of expenditures of Federal awards. Effect: Without periodic training and consistent application of Accountability Lab’s internal policies and procedures, this could potentially result in unreliable and erroneous grant reporting, internal record keeping and decision making. Questioned Costs: None noted. Context: Our audit testwork consisted of substantive procedures over the SEFA. We determined that the issue was systemic in nature. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend Accountability Lab establish internal controls to correctly identify and track all Federal awards received either directly or indirectly.
Finding 2023-001: Preparation of Schedule of Expenditures of Federal Awards (SEFA) Information on the Federal Programs: All Criteria: As noted in 2 CFR 200.508 “Auditee Responsibilities” indicates that the auditee must prepare appropriate financial statements, including the Schedule of Expenditures of Federal Awards (as specifically defined under 2 CFR 200.510 “Financial statements”). Title 2 CFR 200 Section 200.510 “Financial Statements” requires recipients of Federal funds to 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. Additionally, in accordance with CFR 200.303, the non- Federal entity must: establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Accountability Lab experienced difficulty in preparing and ensuring that all Federal expenditures were identified, categorized, and included in the Schedule of Expenditures of Federal Awards. The preparation of Accountability Lab's SEFA required manual adjustments of Federal costs. We noted that the manual adjustments were not completed prior to the start of the audit. We also noted that a certain award was not clearly identified as Federal pass-through funds and therefore not initially included on the SEFA. As a result, several adjustments were posted to the financial statements to ensure Federal receivables, refundable advances and Federal revenue were properly recognized and accurately stated at year-end. Cause: The year-end close process did not provide for the preparation of a complete and accurate schedule of expenditures of Federal awards. Effect: Without periodic training and consistent application of Accountability Lab’s internal policies and procedures, this could potentially result in unreliable and erroneous grant reporting, internal record keeping and decision making. Questioned Costs: None noted. Context: Our audit testwork consisted of substantive procedures over the SEFA. We determined that the issue was systemic in nature. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend Accountability Lab establish internal controls to correctly identify and track all Federal awards received either directly or indirectly.
Finding 2023-001: Preparation of Schedule of Expenditures of Federal Awards (SEFA) Information on the Federal Programs: All Criteria: As noted in 2 CFR 200.508 “Auditee Responsibilities” indicates that the auditee must prepare appropriate financial statements, including the Schedule of Expenditures of Federal Awards (as specifically defined under 2 CFR 200.510 “Financial statements”). Title 2 CFR 200 Section 200.510 “Financial Statements” requires recipients of Federal funds to 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. Additionally, in accordance with CFR 200.303, the non- Federal entity must: establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Accountability Lab experienced difficulty in preparing and ensuring that all Federal expenditures were identified, categorized, and included in the Schedule of Expenditures of Federal Awards. The preparation of Accountability Lab's SEFA required manual adjustments of Federal costs. We noted that the manual adjustments were not completed prior to the start of the audit. We also noted that a certain award was not clearly identified as Federal pass-through funds and therefore not initially included on the SEFA. As a result, several adjustments were posted to the financial statements to ensure Federal receivables, refundable advances and Federal revenue were properly recognized and accurately stated at year-end. Cause: The year-end close process did not provide for the preparation of a complete and accurate schedule of expenditures of Federal awards. Effect: Without periodic training and consistent application of Accountability Lab’s internal policies and procedures, this could potentially result in unreliable and erroneous grant reporting, internal record keeping and decision making. Questioned Costs: None noted. Context: Our audit testwork consisted of substantive procedures over the SEFA. We determined that the issue was systemic in nature. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend Accountability Lab establish internal controls to correctly identify and track all Federal awards received either directly or indirectly.
Finding 2023-001: Preparation of Schedule of Expenditures of Federal Awards (SEFA) Information on the Federal Programs: All Criteria: As noted in 2 CFR 200.508 “Auditee Responsibilities” indicates that the auditee must prepare appropriate financial statements, including the Schedule of Expenditures of Federal Awards (as specifically defined under 2 CFR 200.510 “Financial statements”). Title 2 CFR 200 Section 200.510 “Financial Statements” requires recipients of Federal funds to 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. Additionally, in accordance with CFR 200.303, the non- Federal entity must: establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Accountability Lab experienced difficulty in preparing and ensuring that all Federal expenditures were identified, categorized, and included in the Schedule of Expenditures of Federal Awards. The preparation of Accountability Lab's SEFA required manual adjustments of Federal costs. We noted that the manual adjustments were not completed prior to the start of the audit. We also noted that a certain award was not clearly identified as Federal pass-through funds and therefore not initially included on the SEFA. As a result, several adjustments were posted to the financial statements to ensure Federal receivables, refundable advances and Federal revenue were properly recognized and accurately stated at year-end. Cause: The year-end close process did not provide for the preparation of a complete and accurate schedule of expenditures of Federal awards. Effect: Without periodic training and consistent application of Accountability Lab’s internal policies and procedures, this could potentially result in unreliable and erroneous grant reporting, internal record keeping and decision making. Questioned Costs: None noted. Context: Our audit testwork consisted of substantive procedures over the SEFA. We determined that the issue was systemic in nature. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend Accountability Lab establish internal controls to correctly identify and track all Federal awards received either directly or indirectly.
2023-002 Material Weakness – Preparation of Schedule of Expenditures of Federal and State Awards (“SEFSA”) Statement Condition: Under Uniform Guidance 2 CFR Section 200.508 reporting compliance, it is the auditee’s responsibility to prepare the Schedule of Expenditures of Federal and State Awards statement. The Uniform Guidance 2 CFR Section 200.502 requires the proper tracking and accounting of federal expenditures incurred under the same basis of accounting as the basic financial statements to ensure proper cut-off and timely reporting to the Federal Audit Clearinghouse. Criteria: Procedures should be in place to create a materially accurate Schedule of Expenditures of Federal and State awards statement based on the cash basis of accounting specifically tracking expenses when they are paid. Cause: The procedures in place did not create a materially accurate Schedule of Expenditures of Federal and State awards financial statement for major program compliance. For CFDA #66.458, the SEFSA provided by the Authority did not represent expenditures as paid. This was a result of the bifurcation between loan and grant disbursements, as well as presentation of loan balances on the SEFSA. Uniform Guidance states that SEFSA loan balances should be reported as prior year outstanding loan balance plus current year borrowings. Effect: The fund used to track the expenditures did not properly reflect the federal expenditures incurred in 2023. Recommendation: Procedures should be implemented to create a materially accurate Schedule of Expenditures of Federal and State award financial statement, which should include ascertaining between loan and grant expenditures, and understanding the process for reporting loan balances on the SEFSA. Views of Responsible Officials and Planned Corrective Actions: In order to create a materially accurate Schedule of Expenditures of Federal and State award financial statement, the Authority will establish procedures to ascertain loan and grant expenditures, as well as taking into account the Uniform Guidance requirement for presenting loan balances on the SEFSA.
2023-002 Material Weakness – Preparation of Schedule of Expenditures of Federal and State Awards (“SEFSA”) Statement Condition: Under Uniform Guidance 2 CFR Section 200.508 reporting compliance, it is the auditee’s responsibility to prepare the Schedule of Expenditures of Federal and State Awards statement. The Uniform Guidance 2 CFR Section 200.502 requires the proper tracking and accounting of federal expenditures incurred under the same basis of accounting as the basic financial statements to ensure proper cut-off and timely reporting to the Federal Audit Clearinghouse. Criteria: Procedures should be in place to create a materially accurate Schedule of Expenditures of Federal and State awards statement based on the cash basis of accounting specifically tracking expenses when they are paid. Cause: The procedures in place did not create a materially accurate Schedule of Expenditures of Federal and State awards financial statement for major program compliance. For CFDA #66.458, the SEFSA provided by the Authority did not represent expenditures as paid. This was a result of the bifurcation between loan and grant disbursements, as well as presentation of loan balances on the SEFSA. Uniform Guidance states that SEFSA loan balances should be reported as prior year outstanding loan balance plus current year borrowings. Effect: The fund used to track the expenditures did not properly reflect the federal expenditures incurred in 2023. Recommendation: Procedures should be implemented to create a materially accurate Schedule of Expenditures of Federal and State award financial statement, which should include ascertaining between loan and grant expenditures, and understanding the process for reporting loan balances on the SEFSA. Views of Responsible Officials and Planned Corrective Actions: In order to create a materially accurate Schedule of Expenditures of Federal and State award financial statement, the Authority will establish procedures to ascertain loan and grant expenditures, as well as taking into account the Uniform Guidance requirement for presenting loan balances on the SEFSA.
Finding 2023-002: Schedule of Expenditures of Federal Awards (Significant Deficiency) Federal Program: 93.129 - U.S. Department of Health and Human Services Criteria or Specific Requirement: In accordance with 2 CFR Section 200.508 (b), the Organization is required to prepare appropriate financial statements, including the Schedule of Expenditures of Federal Awards (SEFA). Condition: The Organization included expenditures in its SEFA totaling $9,175 that were in excess of allowable costs for the year ended December 31, 2023. As a result, management provided a revised SEFA after the major program determination had already been completed. Because the Organization had not billed the government for the excess expenditures, there were no questioned costs. Cause: The initial SEFA provided by management at the start of the audit was based on the profit and loss statements, which are used to track both federal and non-federal expenditures. However, the profit and loss statements did not specifically identify the non-federal expenditures which were not allowed to be charged to the federal award. Effect or Potential Effect: The SEFA could have been materially misstated. If the SEFA is not accurately prepared, it could have an effect on the auditor's determination of major programs. Recommendation: The Organization should implement procedures to ensure the accurate preparation of the SEFA prior to the start of the audit.
Finding 2023-002: Schedule of Expenditures of Federal Awards (Significant Deficiency) Federal Program: 93.129 - U.S. Department of Health and Human Services Criteria or Specific Requirement: In accordance with 2 CFR Section 200.508 (b), the Organization is required to prepare appropriate financial statements, including the Schedule of Expenditures of Federal Awards (SEFA). Condition: The Organization included expenditures in its SEFA totaling $9,175 that were in excess of allowable costs for the year ended December 31, 2023. As a result, management provided a revised SEFA after the major program determination had already been completed. Because the Organization had not billed the government for the excess expenditures, there were no questioned costs. Cause: The initial SEFA provided by management at the start of the audit was based on the profit and loss statements, which are used to track both federal and non-federal expenditures. However, the profit and loss statements did not specifically identify the non-federal expenditures which were not allowed to be charged to the federal award. Effect or Potential Effect: The SEFA could have been materially misstated. If the SEFA is not accurately prepared, it could have an effect on the auditor's determination of major programs. Recommendation: The Organization should implement procedures to ensure the accurate preparation of the SEFA prior to the start of the audit.
2023-004 Schedule of Expenditures of Federal Awards Criteria: CFR Part 200.508 Audit Responsibilities state that the auditee must prepare the Schedule of Expenditures of Federal Awards, which must list individual federal awards by federal agency, including the total federal awards expended, name of pass-through entity, assistance listing number, and total amount provided to subrecipients. The information contained in the Schedule of Expenditures of Federal Awards should be derived from and relate directly to the underlying accounting and other records used to prepare the financial statements. Condition: The Schedule of Expenditures of Federal Awards was prepared by the auditor based on federal award contracts provided by the auditee. Also, during 2023 an additional federal award was received that management was not aware of. Cause: Management has limited knowledge on requirements of a Single Audit. Management relied on auditors to prepare the Schedule of Expenditures of Federal Awards. Effect: Potential understatement or overstatement of expenditures could exist in the Schedule of Expenditures of Federal Awards and not be detected or corrected. Questioned Costs: None noted. Recommendation: Establish procedures to prepare the annual Schedule of Expenditures of Federal Awards and reconcile amounts reported to the Organization's general ledger. The Organization should provide appropriate training to staff who work with government funding. Views of Responsible Officials and Planned Corrective Actions: Management will continue to ensure that the Schedule of Expenditures of Federal Awards is complete. Inspiration did prepare the 2023 SEFA, and it was delivered to the auditors immediately in April 2024 at the beginning of our audit.
Finding 2023-003: Error in the 2022 SEFA (Significant Deficiency) Information on the Federal Programs: Both Major Programs Criteria or Specific Requirement: In accordance with 2 CFR Section 200.508 (b), an entity is required to prepare appropriate financial statements, including the Schedule of Expenditures of Federal Awards (SEFA). Condition: Management noted that the 2022 SEFA was understated by $146,051. No issues were noted during the audit regarding the 2023 expenditures reported on the SEFA for the year ended December 31, 2023. Therefore, this compliance finding is not considered to be a material weakness. Cause: While the total expenses reported in the 2022 financial statements was correct, $146,051 of the Federal expenditures were not clearly or properly classified as Federal in the 2022 general ledger. As a result, expenses totaling $146,051 were not included on the 2022 SEFA. Effect or Potential Effect: As a result of the understatement of expenditures reported on the 2022 SEFA, a material misstatement of the 2022 financial statements occurred. In addition, the 2023 SEFA includes the unreported 2022 costs of $146,051. Questioned Costs: None. Repeat Finding: See Finding 2022-006. Recommendation: We recommend that management implement procedures to easily segregate Federal expenditures so that an accurate SEFA can be prepared on a consistent basis.
Finding 2023-003: Error in the 2022 SEFA (Significant Deficiency) Information on the Federal Programs: Both Major Programs Criteria or Specific Requirement: In accordance with 2 CFR Section 200.508 (b), an entity is required to prepare appropriate financial statements, including the Schedule of Expenditures of Federal Awards (SEFA). Condition: Management noted that the 2022 SEFA was understated by $146,051. No issues were noted during the audit regarding the 2023 expenditures reported on the SEFA for the year ended December 31, 2023. Therefore, this compliance finding is not considered to be a material weakness. Cause: While the total expenses reported in the 2022 financial statements was correct, $146,051 of the Federal expenditures were not clearly or properly classified as Federal in the 2022 general ledger. As a result, expenses totaling $146,051 were not included on the 2022 SEFA. Effect or Potential Effect: As a result of the understatement of expenditures reported on the 2022 SEFA, a material misstatement of the 2022 financial statements occurred. In addition, the 2023 SEFA includes the unreported 2022 costs of $146,051. Questioned Costs: None. Repeat Finding: See Finding 2022-006. Recommendation: We recommend that management implement procedures to easily segregate Federal expenditures so that an accurate SEFA can be prepared on a consistent basis.
Highway Planning and Construction - Assistance Listing No. 20.205; Passed through Pennsylvania Department of Transportation, Grant Period - Year Ended December 31, 2023. Material Weakness: See deficiency 2023-002 in Section II - listed below 2023-002. SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS -Criteria: The Township must prepare appropriate financial statements, including the schedule of expenditures of federal awards (SEFA), in accordance with Title 2 CFR Sections 200.510(b) and 200.508(b) of the Uniform Guidance. The preparation of the SEFA assists the Township in determining whether it has a Single Audit reporting requirement. Condition: Although management prepared a draft of the SEFA, it was incomplete and contained inaccurate information. Cause: Management did not identify all of the Township’s federal expenditures. Effect: Prior to adjustment, federal expenditures were materially misstated. Questioned Costs: Not applicable. Perspective Information: Not applicable. Identification of Repeat Findings: Not applicable. Recommendation: The Township should establish procedures to identify all expenditures and reporting requirements of its federal programs. Views of Responsible Officials: Management agrees with the finding. Planned Corrective Action: See Township’s corrective action plan.
Finding 2023-003: Schedule of Expenditures of Federal Awards (Significant Deficiency) Information on the Federal Program: All programs in the 2023 SEFA. See Finding 2023-002.Criteria: In accordance with 2 CFR Section 200.508 (b), USTTI is required to prepare appropriate financial statements, including the Schedule of Expenditures of Federal Awards (SEFA). Condition: USTTI experienced difficulty in ensuring that all Federal expenditures were identified, categorized and included in the SEFA. Due to the amount of program codes in the accounting system, it was difficult to identify which subprogram codes related to the various Federal programs. In addition, indirect costs reported to the Federal granting agencies were not properly calculated. This condition impacted the entire SEFA and is considered to be a systematic problem. Cause: The high volume of subprogram codes was a contributing factor to the error as well as the improper calculation of the indirect costs on the grants. Effect: USTTI experienced difficulty in preparing an accurate SEFA. Context: USTTI does not have processes and procedures in place to prepare an accurate SEFA.Questioned Costs: None. Identification as a Repeat Finding: Yes. See Finding 2022-002.Recommendation: We recommend USTTI prepare its SEFA on a quarterly basis in accordance with the Uniform Guidance, and it should be reviewed and approved by an individual in a supervisory capacity with knowledge of the grant program. USTTI should ensure that the review process encompasses agreeing the amounts in the SEFA to expenses recorded in the general ledger. Additionally, USTTI should review the indirect rate calculation to ensure that is is accurate and that USTTI is not charging more indirect costs than allowed in accordance with the terms of its grant.
Finding 2023-003: Schedule of Expenditures of Federal Awards (Significant Deficiency) Information on the Federal Program: All programs in the 2023 SEFA. See Finding 2023-002.Criteria: In accordance with 2 CFR Section 200.508 (b), USTTI is required to prepare appropriate financial statements, including the Schedule of Expenditures of Federal Awards (SEFA). Condition: USTTI experienced difficulty in ensuring that all Federal expenditures were identified, categorized and included in the SEFA. Due to the amount of program codes in the accounting system, it was difficult to identify which subprogram codes related to the various Federal programs. In addition, indirect costs reported to the Federal granting agencies were not properly calculated. This condition impacted the entire SEFA and is considered to be a systematic problem. Cause: The high volume of subprogram codes was a contributing factor to the error as well as the improper calculation of the indirect costs on the grants. Effect: USTTI experienced difficulty in preparing an accurate SEFA. Context: USTTI does not have processes and procedures in place to prepare an accurate SEFA.Questioned Costs: None. Identification as a Repeat Finding: Yes. See Finding 2022-002.Recommendation: We recommend USTTI prepare its SEFA on a quarterly basis in accordance with the Uniform Guidance, and it should be reviewed and approved by an individual in a supervisory capacity with knowledge of the grant program. USTTI should ensure that the review process encompasses agreeing the amounts in the SEFA to expenses recorded in the general ledger. Additionally, USTTI should review the indirect rate calculation to ensure that is is accurate and that USTTI is not charging more indirect costs than allowed in accordance with the terms of its grant.
#2023-005 – Assistance Listing Number 14.155 Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects, U.S. Department of Housing and Urban Development Material Weakness in Internal Control and Failure to Comply with Federal Requirements of Contracts. Criteria: The Uniform Guidance – 2 CFR §200.508(b) and 2 CFR §200.508(d) – state: “The auditee must: …(b) Prepare appropriate financial statements, including the schedule of Federal awards in accordance with §200.510…(d) Provide the auditor with access to personnel, accounts, books, records, supporting documentation, and other information as needed for the auditor to perform the audit required by this part.” Statement of Condition: Management was unable to provide written internal controls over financial statement preparation, operations and federal awards. Cause: Management’s lack of knowledge of the Code of Federal Regulations. Effect: Corporation was not in compliance with 2 CFR §200. This contributed to the general ledger being incomplete and inaccurate. Recommendation: Management should establish written internal controls that document the controls over financial statement preparation, operations and federal awards. Questioned costs: None.
Finding SA 2023-002 Reporting: Late Submission of Single Audit Reporting Package Criteria Per 2 CFR §200.508(a) and §200.512(a) of the Uniform Guidance, entities that expend $750,000 or more in federal awards in a fiscal year must arrange for an audit in accordance with 2 CFR 200.509 and submit the Single Audit reporting package to the Federal Audit Clearinghouse (FAC) no later than nine months after the end of the fiscal year or 30 days after the receipt of the audit report, whichever is earlier. Timely submission is critical to ensure compliance with federal requirements and continued eligibility for federal funding. Condition The Organization did not submit the Single Audit reporting packages for the 2022 and 2023 audits within the required reporting timeline. Cause/Effect The late submission was due to delays in the Organization’s financial closing process. This non-compliance with the Uniform Guidance may result in the imposition of penalties and/or unnecessary costs. Questioned Costs None Recommendation We recommend that the Organization strengthen its internal controls over its financial accounting and reporting process to ensure consistent compliance with the Uniform Guidance. Views of responsible officials and planned corrective actions: The Organization’s Accounting Department, under the direction of the Chief Executive Officer, Connie Franks will ensure that there’s proactive communication, dedicated resource allocation, and regular status checks on the deadline. He should ensure everyone involved understands the deadlines and responsibilities to avoid any delays. Completion of the referenced corrective action will be implemented by January 2025.
2023-001 Schedule of Expenditures of Federal Awards (Material Weakness) U.S. Department of Treasury 21.027 Coronavirus State and Local Fiscal Recovery Funds U.S. Department of Treasury 93.959 Block Grants for Prevention and Treatment of Substance Abuse Criteria: CFR Part 200.508 Audit Responsibilities state that the auditee must prepare the Schedule of Expenditures of Federal Awards, which must list individual federal awards by federal agency, including the total federal awards expended, name of pass-through entity, assistance listing number, and total amount provided to subrecipients. The information contained in the Schedule of Expenditures of Federal Awards should be derived from and relate directly to the underlying accounting and other records used to prepare the financial statements. Condition: The Schedule of Expenditures of Federal Awards was prepared by the auditor based on federal award contracts provided by auditee. Auditee was not aware of federal sources of funding. Cause: Management has limited knowledge on requirements of a Single Audit. Management relied on auditors to prepare the Schedule of Expenditures of Federal Awards. Effect: Potential understatement or overstatement of expenditures could exist in the Schedule of Expenditures of Federal Awards and not be detected or corrected. Questioned Costs: None noted. Recommendation: Establish procedures to prepare the annual Schedule of Expenditures of Federal Awards and reconcile amounts reported to the Organization's general ledger. The Organization should provide appropriate training to staff who work with government funding. Views of Responsible Officials and Planned Corrective Actions: The Organization will prepare a current Scheduel of Expenditures of Federal Awards, listing awards by federal agency, total federal awards expended, name of pass-through entity, assistance listing number, and total amount provided to subrecipients. Monique Johnson, Executive Director of Allen County Drug & Alcohol Consortium, is responsible for this corrective action. The anticipated completion date is April 15, 2025.
2023-001 Schedule of Expenditures of Federal Awards (Material Weakness) U.S. Department of Treasury 21.027 Coronavirus State and Local Fiscal Recovery Funds U.S. Department of Treasury 93.959 Block Grants for Prevention and Treatment of Substance Abuse Criteria: CFR Part 200.508 Audit Responsibilities state that the auditee must prepare the Schedule of Expenditures of Federal Awards, which must list individual federal awards by federal agency, including the total federal awards expended, name of pass-through entity, assistance listing number, and total amount provided to subrecipients. The information contained in the Schedule of Expenditures of Federal Awards should be derived from and relate directly to the underlying accounting and other records used to prepare the financial statements. Condition: The Schedule of Expenditures of Federal Awards was prepared by the auditor based on federal award contracts provided by auditee. Auditee was not aware of federal sources of funding. Cause: Management has limited knowledge on requirements of a Single Audit. Management relied on auditors to prepare the Schedule of Expenditures of Federal Awards. Effect: Potential understatement or overstatement of expenditures could exist in the Schedule of Expenditures of Federal Awards and not be detected or corrected. Questioned Costs: None noted. Recommendation: Establish procedures to prepare the annual Schedule of Expenditures of Federal Awards and reconcile amounts reported to the Organization's general ledger. The Organization should provide appropriate training to staff who work with government funding. Views of Responsible Officials and Planned Corrective Actions: The Organization will prepare a current Scheduel of Expenditures of Federal Awards, listing awards by federal agency, total federal awards expended, name of pass-through entity, assistance listing number, and total amount provided to subrecipients. Monique Johnson, Executive Director of Allen County Drug & Alcohol Consortium, is responsible for this corrective action. The anticipated completion date is April 15, 2025.
Condition: The Organization's Schedule of Expenditures of Federal Awards (SEFA) inaccurately presented the federal expenditures for the federal awards. The Organization's SEFA was prepared of of September 30, 2023 and not their fiscal year, December 31, 2023. Criteria: Internal controls should be in place to provide reasonable assurance that the SEFA is prepared in accordance with the Uniform Guidance. The Uniform Guidance, at 2 CFR section 200.508(b), requires the Organization to prepare appropriate financial statements, including the SEFA. Cause: A reconciliation to the related expenditures from federal awards was not performed and would have identified the noted misstatement of the SEFA. Effect: Lack of effective controls in place over the financial reporting function increases the risk of misstatements, fraud, or errors occurring and not being detected and corrected in a timely manner. Recommendation: The Organization should have effective internal controls in place to ensure that the SEFA is accurately prepared and reconciles to the related revenues and expenses recorded in the financial statements.
Schedule of Expenditures of Federal Awards Federal Agency: U.S. Department of Treasury Federal Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: ISA-ARPA-ADWR-123022-01 - 2023 Pass-Through Agency: State of Arizona Governor’s Office Pass-Through Number(s): ERMT-20-002 Award Period: January 1, 2023 through January 1, 2026 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Under the U.S. Code of Federal Regulations Title 2, Part 200, Subpart F, Uniform Administrative requires certain auditee responsibilities identified in § 200.508 including the appropriate preparation of financial statements, including the schedule of expenditures of federal awards in accordance with § 200.510. Condition: The District's SEFA was overstated and revised by a known amount of $117,462 comprised of invoices incurred prior to the ARPA act that should not have been submitted under their ARPA grant allocation. Questioned costs: None Context: During our reconciliation of the schedule of expenditures of federal awards (SEFA) to the District's general ledger and invoice listings, it was determined various invoices for inventory/supplies purchases made prior to the ARPA act beginning period of July 1, 2021 were submitted for reimbursement under their ARPA allocation and were presented on the SEFA. The total overstatement and revision of the SEFA was $117,462. Cause: The District does not have effective internal controls in place to ensure compliance with the Uniform Guidance. Effect: The lack of internal controls over the provisions of allowable costs and period of performance compliance requirements provides an opportunity for noncompliance. Repeat Finding: No. Recommendation: We recommend the District design controls to ensure an adequate review process over the invoices recorded and presented on the schedule of expenditures of federal awards to determine compliance with the Uniform Guidance. Views of responsible officials and planned corrective actions: Management concurs with the finding, and as reported in the corrective action plan, District policies will be updated and approved to conform to federal guidance.
2023-002 - Deficiency in Internal Controls Over SEFA Preparation and Material Adjustments Finding Type: Material Weakness in Internal Control Over Compliance Programs: Coronavirus State and Local Fiscal Recovery Funds (Assistance Listing Number 21.027) and Capitalization Grants for Clean Water State Revolving Funds (Assistance Listing Number 66.458) Criteria: According to 2 CFR § 200.508(b), the auditee is responsible for preparing appropriate financial statements, including the Schedule of Expenditures of Federal Awards (SEFA). The Uniform Guidance requires that auditees maintain adequate internal controls over financial reporting to ensure that financial statements and the SEFA are accurate, complete, and prepared in accordance with applicable regulations. Condition/Finding: During the course of our federal single audit, it was observed that the Schedule of Expenditures of Federal Awards (“SEFA”) was prepared by the auditor instead of the Township. Although the Township reviewed and accepted the SEFA, the preparation was not independently performed by the Township. Additionally, the auditor proposed and the Township accepted material proposed audit adjusting journal entries that impacted the federal awards reported on the SEFA. Cause: The Township lacks sufficient staff with the necessary skills and knowledge to independently prepare the SEFA. As a result, the Township relies on the auditor to compile this schedule and to propose material audit adjustments. The Township has limited resources, which contributes to this reliance. Effect: Reliance on the auditor to prepare the SEFA and to propose material audit adjustments indicates a deficiency in the Township’s internal controls over financial reporting. This situation increases the risk that the SEFA may not be accurately or completely prepared if the auditor does not perform these tasks. Additionally, this reliance could potentially result in a significant deficiency or material weakness in the Township’s internal control over financial reporting. Questioned Costs: No costs have been questioned as a result of this finding. Repeat Finding: No Recommendation: To correct this finding in the future, we recommend that the Township take the following actions: 1. Staff Training: Provide additional training to current staff on the requirements and preparation of the SEFA to build the necessary skills and knowledge internally. 2. Develop Detailed Procedures: Develop and document detailed procedures and guidelines for preparing the SEFA, including checklists and timelines, to assist staff in the accurate preparation of this schedule. 3. Review and Approval Process: Establish a robust review and approval process where a knowledgeable individual within the organization reviews the SEFA for accuracy and completeness before submission. 4. Improve Internal Controls: Enhance internal controls over financial reporting to ensure that material audit adjustments are minimized and that the financial statements and SEFA are prepared accurately and independently. View of Responsible Officials (Corrective Action): See corrective action plan.
2023-002 - Deficiency in Internal Controls Over SEFA Preparation and Material Adjustments Finding Type: Material Weakness in Internal Control Over Compliance Programs: Coronavirus State and Local Fiscal Recovery Funds (Assistance Listing Number 21.027) and Capitalization Grants for Clean Water State Revolving Funds (Assistance Listing Number 66.458) Criteria: According to 2 CFR § 200.508(b), the auditee is responsible for preparing appropriate financial statements, including the Schedule of Expenditures of Federal Awards (SEFA). The Uniform Guidance requires that auditees maintain adequate internal controls over financial reporting to ensure that financial statements and the SEFA are accurate, complete, and prepared in accordance with applicable regulations. Condition/Finding: During the course of our federal single audit, it was observed that the Schedule of Expenditures of Federal Awards (“SEFA”) was prepared by the auditor instead of the Township. Although the Township reviewed and accepted the SEFA, the preparation was not independently performed by the Township. Additionally, the auditor proposed and the Township accepted material proposed audit adjusting journal entries that impacted the federal awards reported on the SEFA. Cause: The Township lacks sufficient staff with the necessary skills and knowledge to independently prepare the SEFA. As a result, the Township relies on the auditor to compile this schedule and to propose material audit adjustments. The Township has limited resources, which contributes to this reliance. Effect: Reliance on the auditor to prepare the SEFA and to propose material audit adjustments indicates a deficiency in the Township’s internal controls over financial reporting. This situation increases the risk that the SEFA may not be accurately or completely prepared if the auditor does not perform these tasks. Additionally, this reliance could potentially result in a significant deficiency or material weakness in the Township’s internal control over financial reporting. Questioned Costs: No costs have been questioned as a result of this finding. Repeat Finding: No Recommendation: To correct this finding in the future, we recommend that the Township take the following actions: 1. Staff Training: Provide additional training to current staff on the requirements and preparation of the SEFA to build the necessary skills and knowledge internally. 2. Develop Detailed Procedures: Develop and document detailed procedures and guidelines for preparing the SEFA, including checklists and timelines, to assist staff in the accurate preparation of this schedule. 3. Review and Approval Process: Establish a robust review and approval process where a knowledgeable individual within the organization reviews the SEFA for accuracy and completeness before submission. 4. Improve Internal Controls: Enhance internal controls over financial reporting to ensure that material audit adjustments are minimized and that the financial statements and SEFA are prepared accurately and independently. View of Responsible Officials (Corrective Action): See corrective action plan.
2023-002 - Deficiency in Internal Controls Over SEFA Preparation and Material Adjustments Finding Type: Material Weakness in Internal Control Over Compliance Programs: Coronavirus State and Local Fiscal Recovery Funds (Assistance Listing Number 21.027) and Capitalization Grants for Clean Water State Revolving Funds (Assistance Listing Number 66.458) Criteria: According to 2 CFR § 200.508(b), the auditee is responsible for preparing appropriate financial statements, including the Schedule of Expenditures of Federal Awards (SEFA). The Uniform Guidance requires that auditees maintain adequate internal controls over financial reporting to ensure that financial statements and the SEFA are accurate, complete, and prepared in accordance with applicable regulations. Condition/Finding: During the course of our federal single audit, it was observed that the Schedule of Expenditures of Federal Awards (“SEFA”) was prepared by the auditor instead of the Township. Although the Township reviewed and accepted the SEFA, the preparation was not independently performed by the Township. Additionally, the auditor proposed and the Township accepted material proposed audit adjusting journal entries that impacted the federal awards reported on the SEFA. Cause: The Township lacks sufficient staff with the necessary skills and knowledge to independently prepare the SEFA. As a result, the Township relies on the auditor to compile this schedule and to propose material audit adjustments. The Township has limited resources, which contributes to this reliance. Effect: Reliance on the auditor to prepare the SEFA and to propose material audit adjustments indicates a deficiency in the Township’s internal controls over financial reporting. This situation increases the risk that the SEFA may not be accurately or completely prepared if the auditor does not perform these tasks. Additionally, this reliance could potentially result in a significant deficiency or material weakness in the Township’s internal control over financial reporting. Questioned Costs: No costs have been questioned as a result of this finding. Repeat Finding: No Recommendation: To correct this finding in the future, we recommend that the Township take the following actions: 1. Staff Training: Provide additional training to current staff on the requirements and preparation of the SEFA to build the necessary skills and knowledge internally. 2. Develop Detailed Procedures: Develop and document detailed procedures and guidelines for preparing the SEFA, including checklists and timelines, to assist staff in the accurate preparation of this schedule. 3. Review and Approval Process: Establish a robust review and approval process where a knowledgeable individual within the organization reviews the SEFA for accuracy and completeness before submission. 4. Improve Internal Controls: Enhance internal controls over financial reporting to ensure that material audit adjustments are minimized and that the financial statements and SEFA are prepared accurately and independently. View of Responsible Officials (Corrective Action): See corrective action plan.
Finding 2023-001: Preparation of Schedule of Expenditures of Federal Awards (SEFA) Information on the Federal Programs: All Criteria: As noted in 2 CFR 200.508 “Auditee Responsibilities” indicates that the auditee must prepare appropriate financial statements, including the Schedule of Expenditures of Federal Awards (as specifically defined under 2 CFR 200.510 “Financial statements”). Title 2 CFR 200 Section 200.510 “Financial Statements” requires recipients of Federal funds to 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. Additionally, in accordance with CFR 200.303, the non- Federal entity must: establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Accountability Lab experienced difficulty in preparing and ensuring that all Federal expenditures were identified, categorized, and included in the Schedule of Expenditures of Federal Awards. The preparation of Accountability Lab's SEFA required manual adjustments of Federal costs. We noted that the manual adjustments were not completed prior to the start of the audit. We also noted that a certain award was not clearly identified as Federal pass-through funds and therefore not initially included on the SEFA. As a result, several adjustments were posted to the financial statements to ensure Federal receivables, refundable advances and Federal revenue were properly recognized and accurately stated at year-end. Cause: The year-end close process did not provide for the preparation of a complete and accurate schedule of expenditures of Federal awards. Effect: Without periodic training and consistent application of Accountability Lab’s internal policies and procedures, this could potentially result in unreliable and erroneous grant reporting, internal record keeping and decision making. Questioned Costs: None noted. Context: Our audit testwork consisted of substantive procedures over the SEFA. We determined that the issue was systemic in nature. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend Accountability Lab establish internal controls to correctly identify and track all Federal awards received either directly or indirectly.
Finding 2023-001: Preparation of Schedule of Expenditures of Federal Awards (SEFA) Information on the Federal Programs: All Criteria: As noted in 2 CFR 200.508 “Auditee Responsibilities” indicates that the auditee must prepare appropriate financial statements, including the Schedule of Expenditures of Federal Awards (as specifically defined under 2 CFR 200.510 “Financial statements”). Title 2 CFR 200 Section 200.510 “Financial Statements” requires recipients of Federal funds to 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. Additionally, in accordance with CFR 200.303, the non- Federal entity must: establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Accountability Lab experienced difficulty in preparing and ensuring that all Federal expenditures were identified, categorized, and included in the Schedule of Expenditures of Federal Awards. The preparation of Accountability Lab's SEFA required manual adjustments of Federal costs. We noted that the manual adjustments were not completed prior to the start of the audit. We also noted that a certain award was not clearly identified as Federal pass-through funds and therefore not initially included on the SEFA. As a result, several adjustments were posted to the financial statements to ensure Federal receivables, refundable advances and Federal revenue were properly recognized and accurately stated at year-end. Cause: The year-end close process did not provide for the preparation of a complete and accurate schedule of expenditures of Federal awards. Effect: Without periodic training and consistent application of Accountability Lab’s internal policies and procedures, this could potentially result in unreliable and erroneous grant reporting, internal record keeping and decision making. Questioned Costs: None noted. Context: Our audit testwork consisted of substantive procedures over the SEFA. We determined that the issue was systemic in nature. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend Accountability Lab establish internal controls to correctly identify and track all Federal awards received either directly or indirectly.
Finding 2023-001: Preparation of Schedule of Expenditures of Federal Awards (SEFA) Information on the Federal Programs: All Criteria: As noted in 2 CFR 200.508 “Auditee Responsibilities” indicates that the auditee must prepare appropriate financial statements, including the Schedule of Expenditures of Federal Awards (as specifically defined under 2 CFR 200.510 “Financial statements”). Title 2 CFR 200 Section 200.510 “Financial Statements” requires recipients of Federal funds to 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. Additionally, in accordance with CFR 200.303, the non- Federal entity must: establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Accountability Lab experienced difficulty in preparing and ensuring that all Federal expenditures were identified, categorized, and included in the Schedule of Expenditures of Federal Awards. The preparation of Accountability Lab's SEFA required manual adjustments of Federal costs. We noted that the manual adjustments were not completed prior to the start of the audit. We also noted that a certain award was not clearly identified as Federal pass-through funds and therefore not initially included on the SEFA. As a result, several adjustments were posted to the financial statements to ensure Federal receivables, refundable advances and Federal revenue were properly recognized and accurately stated at year-end. Cause: The year-end close process did not provide for the preparation of a complete and accurate schedule of expenditures of Federal awards. Effect: Without periodic training and consistent application of Accountability Lab’s internal policies and procedures, this could potentially result in unreliable and erroneous grant reporting, internal record keeping and decision making. Questioned Costs: None noted. Context: Our audit testwork consisted of substantive procedures over the SEFA. We determined that the issue was systemic in nature. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend Accountability Lab establish internal controls to correctly identify and track all Federal awards received either directly or indirectly.
Finding 2023-001: Preparation of Schedule of Expenditures of Federal Awards (SEFA) Information on the Federal Programs: All Criteria: As noted in 2 CFR 200.508 “Auditee Responsibilities” indicates that the auditee must prepare appropriate financial statements, including the Schedule of Expenditures of Federal Awards (as specifically defined under 2 CFR 200.510 “Financial statements”). Title 2 CFR 200 Section 200.510 “Financial Statements” requires recipients of Federal funds to 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. Additionally, in accordance with CFR 200.303, the non- Federal entity must: establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Accountability Lab experienced difficulty in preparing and ensuring that all Federal expenditures were identified, categorized, and included in the Schedule of Expenditures of Federal Awards. The preparation of Accountability Lab's SEFA required manual adjustments of Federal costs. We noted that the manual adjustments were not completed prior to the start of the audit. We also noted that a certain award was not clearly identified as Federal pass-through funds and therefore not initially included on the SEFA. As a result, several adjustments were posted to the financial statements to ensure Federal receivables, refundable advances and Federal revenue were properly recognized and accurately stated at year-end. Cause: The year-end close process did not provide for the preparation of a complete and accurate schedule of expenditures of Federal awards. Effect: Without periodic training and consistent application of Accountability Lab’s internal policies and procedures, this could potentially result in unreliable and erroneous grant reporting, internal record keeping and decision making. Questioned Costs: None noted. Context: Our audit testwork consisted of substantive procedures over the SEFA. We determined that the issue was systemic in nature. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend Accountability Lab establish internal controls to correctly identify and track all Federal awards received either directly or indirectly.
Finding 2023-001: Preparation of Schedule of Expenditures of Federal Awards (SEFA) Information on the Federal Programs: All Criteria: As noted in 2 CFR 200.508 “Auditee Responsibilities” indicates that the auditee must prepare appropriate financial statements, including the Schedule of Expenditures of Federal Awards (as specifically defined under 2 CFR 200.510 “Financial statements”). Title 2 CFR 200 Section 200.510 “Financial Statements” requires recipients of Federal funds to 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. Additionally, in accordance with CFR 200.303, the non- Federal entity must: establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Accountability Lab experienced difficulty in preparing and ensuring that all Federal expenditures were identified, categorized, and included in the Schedule of Expenditures of Federal Awards. The preparation of Accountability Lab's SEFA required manual adjustments of Federal costs. We noted that the manual adjustments were not completed prior to the start of the audit. We also noted that a certain award was not clearly identified as Federal pass-through funds and therefore not initially included on the SEFA. As a result, several adjustments were posted to the financial statements to ensure Federal receivables, refundable advances and Federal revenue were properly recognized and accurately stated at year-end. Cause: The year-end close process did not provide for the preparation of a complete and accurate schedule of expenditures of Federal awards. Effect: Without periodic training and consistent application of Accountability Lab’s internal policies and procedures, this could potentially result in unreliable and erroneous grant reporting, internal record keeping and decision making. Questioned Costs: None noted. Context: Our audit testwork consisted of substantive procedures over the SEFA. We determined that the issue was systemic in nature. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend Accountability Lab establish internal controls to correctly identify and track all Federal awards received either directly or indirectly.
Finding 2023-001: Preparation of Schedule of Expenditures of Federal Awards (SEFA) Information on the Federal Programs: All Criteria: As noted in 2 CFR 200.508 “Auditee Responsibilities” indicates that the auditee must prepare appropriate financial statements, including the Schedule of Expenditures of Federal Awards (as specifically defined under 2 CFR 200.510 “Financial statements”). Title 2 CFR 200 Section 200.510 “Financial Statements” requires recipients of Federal funds to 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. Additionally, in accordance with CFR 200.303, the non- Federal entity must: establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Accountability Lab experienced difficulty in preparing and ensuring that all Federal expenditures were identified, categorized, and included in the Schedule of Expenditures of Federal Awards. The preparation of Accountability Lab's SEFA required manual adjustments of Federal costs. We noted that the manual adjustments were not completed prior to the start of the audit. We also noted that a certain award was not clearly identified as Federal pass-through funds and therefore not initially included on the SEFA. As a result, several adjustments were posted to the financial statements to ensure Federal receivables, refundable advances and Federal revenue were properly recognized and accurately stated at year-end. Cause: The year-end close process did not provide for the preparation of a complete and accurate schedule of expenditures of Federal awards. Effect: Without periodic training and consistent application of Accountability Lab’s internal policies and procedures, this could potentially result in unreliable and erroneous grant reporting, internal record keeping and decision making. Questioned Costs: None noted. Context: Our audit testwork consisted of substantive procedures over the SEFA. We determined that the issue was systemic in nature. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend Accountability Lab establish internal controls to correctly identify and track all Federal awards received either directly or indirectly.
Finding 2023-001: Preparation of Schedule of Expenditures of Federal Awards (SEFA) Information on the Federal Programs: All Criteria: As noted in 2 CFR 200.508 “Auditee Responsibilities” indicates that the auditee must prepare appropriate financial statements, including the Schedule of Expenditures of Federal Awards (as specifically defined under 2 CFR 200.510 “Financial statements”). Title 2 CFR 200 Section 200.510 “Financial Statements” requires recipients of Federal funds to 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. Additionally, in accordance with CFR 200.303, the non- Federal entity must: establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Accountability Lab experienced difficulty in preparing and ensuring that all Federal expenditures were identified, categorized, and included in the Schedule of Expenditures of Federal Awards. The preparation of Accountability Lab's SEFA required manual adjustments of Federal costs. We noted that the manual adjustments were not completed prior to the start of the audit. We also noted that a certain award was not clearly identified as Federal pass-through funds and therefore not initially included on the SEFA. As a result, several adjustments were posted to the financial statements to ensure Federal receivables, refundable advances and Federal revenue were properly recognized and accurately stated at year-end. Cause: The year-end close process did not provide for the preparation of a complete and accurate schedule of expenditures of Federal awards. Effect: Without periodic training and consistent application of Accountability Lab’s internal policies and procedures, this could potentially result in unreliable and erroneous grant reporting, internal record keeping and decision making. Questioned Costs: None noted. Context: Our audit testwork consisted of substantive procedures over the SEFA. We determined that the issue was systemic in nature. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend Accountability Lab establish internal controls to correctly identify and track all Federal awards received either directly or indirectly.
2023-002 Material Weakness – Preparation of Schedule of Expenditures of Federal and State Awards (“SEFSA”) Statement Condition: Under Uniform Guidance 2 CFR Section 200.508 reporting compliance, it is the auditee’s responsibility to prepare the Schedule of Expenditures of Federal and State Awards statement. The Uniform Guidance 2 CFR Section 200.502 requires the proper tracking and accounting of federal expenditures incurred under the same basis of accounting as the basic financial statements to ensure proper cut-off and timely reporting to the Federal Audit Clearinghouse. Criteria: Procedures should be in place to create a materially accurate Schedule of Expenditures of Federal and State awards statement based on the cash basis of accounting specifically tracking expenses when they are paid. Cause: The procedures in place did not create a materially accurate Schedule of Expenditures of Federal and State awards financial statement for major program compliance. For CFDA #66.458, the SEFSA provided by the Authority did not represent expenditures as paid. This was a result of the bifurcation between loan and grant disbursements, as well as presentation of loan balances on the SEFSA. Uniform Guidance states that SEFSA loan balances should be reported as prior year outstanding loan balance plus current year borrowings. Effect: The fund used to track the expenditures did not properly reflect the federal expenditures incurred in 2023. Recommendation: Procedures should be implemented to create a materially accurate Schedule of Expenditures of Federal and State award financial statement, which should include ascertaining between loan and grant expenditures, and understanding the process for reporting loan balances on the SEFSA. Views of Responsible Officials and Planned Corrective Actions: In order to create a materially accurate Schedule of Expenditures of Federal and State award financial statement, the Authority will establish procedures to ascertain loan and grant expenditures, as well as taking into account the Uniform Guidance requirement for presenting loan balances on the SEFSA.
2023-002 Material Weakness – Preparation of Schedule of Expenditures of Federal and State Awards (“SEFSA”) Statement Condition: Under Uniform Guidance 2 CFR Section 200.508 reporting compliance, it is the auditee’s responsibility to prepare the Schedule of Expenditures of Federal and State Awards statement. The Uniform Guidance 2 CFR Section 200.502 requires the proper tracking and accounting of federal expenditures incurred under the same basis of accounting as the basic financial statements to ensure proper cut-off and timely reporting to the Federal Audit Clearinghouse. Criteria: Procedures should be in place to create a materially accurate Schedule of Expenditures of Federal and State awards statement based on the cash basis of accounting specifically tracking expenses when they are paid. Cause: The procedures in place did not create a materially accurate Schedule of Expenditures of Federal and State awards financial statement for major program compliance. For CFDA #66.458, the SEFSA provided by the Authority did not represent expenditures as paid. This was a result of the bifurcation between loan and grant disbursements, as well as presentation of loan balances on the SEFSA. Uniform Guidance states that SEFSA loan balances should be reported as prior year outstanding loan balance plus current year borrowings. Effect: The fund used to track the expenditures did not properly reflect the federal expenditures incurred in 2023. Recommendation: Procedures should be implemented to create a materially accurate Schedule of Expenditures of Federal and State award financial statement, which should include ascertaining between loan and grant expenditures, and understanding the process for reporting loan balances on the SEFSA. Views of Responsible Officials and Planned Corrective Actions: In order to create a materially accurate Schedule of Expenditures of Federal and State award financial statement, the Authority will establish procedures to ascertain loan and grant expenditures, as well as taking into account the Uniform Guidance requirement for presenting loan balances on the SEFSA.