Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP) ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program) ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B Federal Award Identification Number and Year Various Pass-through Entity - N/A for ALN 21.023, 20.505, 93.145, and 93.686 ALN 20.205 is passed through Michigan Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. ALN 93.323 is passed through Michigan Department of Health and Human Services. ALN 97.036 is directly funded and passed through Michigan Department of Health and Human Services and Michigan State Police. ALN 93.323 is passed through Michigan Department of Health and Human Services. Finding Type - Material weakness Repeat Finding - Yes - 2021-013 Criteria - Per 2 CFR 200.510(b)-The auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended as determined in accordance with ? 200.502. While not required, the auditee may choose to provide information requested by federal awarding agencies and pass-through entities to make the schedule easier to use. Condition - The schedule of expenditures of federal awards (SEFA) was not complete, accurate, or prepared timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In fiscal year 2022, the City expended approximately $229.7 million of federal funding. The funding was received by various departments within the City from several federal and nonfederal entities. The City accumulates the financial data and other required information to complete the SEFA. The SEFA included the following inaccuracies: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were understated by $1,868,133 related to the June 30, 2022 accrual. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster, ALN 20.500, instead of the Highway Planning and Construction Cluster. ? ALN 20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research. - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster, ALN 20.516 and 20.521. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $283,851 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323 (ELC). ? ALN 93.268 Immunizations Cooperative Agreements Expenditures of $1,698,773 were improperly excluded from the SEFA. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America - Ryan White HIV/AIDS Program Parts A and B - Expenditures of $240,000 were improperly reported as ALN 93.686 instead of ALN 93.145. Cause and Effect - Controls in place did not ensure the SEFA was completed in a timely manner and that it was complete and accurate. The resulting errors had the following impact: ? ALN 21.023 (ERAP) - The expenditures reported on the SEFA were initially understated by $1,868,133. ? ALN 20.205 Highway Planning and Construction program - Expenditures of $2,027,058 were improperly included under the Federal Transit Cluster instead of the Highway Planning and Construction Cluster resulting in the Highway Planning and Construction Cluster being a Type B program ? ALN 20.505 Metropolitan Transportation Planning and State and Non Metropolitan Planning and Research - Expenditures of $249,939 was improperly included under the Transit Services Program Cluster. ? ALN 93.323 (ELC) and ALN 97.036 (FEMA) - $1,371,758 spent under ALN 97.036 (FEMA) was improperly reported under ALN 93.323, (ELC). The initial understatement of FEMA expenditures impacted major program determination. ? ALN 93.268 Total Immunizations Cooperative Agreements - The expenditures reported on the SEFA were initially understated by $283,851. ? ALN 93.145, HIV Related Training and Technical Assistance and ALN 93.686, Ending the HIV Pandemic: A Plan for America Ryan White HIV/AIDS Program Parts A and B - $240,000 spent under ALN 93.145 were improperly included in ALN 93.686. These errors, noted above, have been corrected on the SEFA as of June 30, 2022. Recommendation - The City should implement process to ensure that the SEFA is prepared timely and that it is complete and accurate. Views of Responsible Officials and Planned Corrective Actions - As part of the City Audit Finding Corrective Action Plan, in FY22, the City developed a SEFA checklist to help ensure all federal expenditures are properly reported. A follow up AFCAP will be implemented and additional processes put in place by management that will provide timelines, a pre SEFA reporting review before the year end close to effectively meet audit report timelines and help ensure completeness, validity, and accuracy in advance of the final SEFA reporting.
2022-005 ? Material Weakness and Noncompliance: Preparation of Schedule of Expenditures of Federal Awards (SEFA) Finding Type: Material Weakness in Internal Controls and Noncompliance (Reporting and Allowable Costs/Cost Principles) Federal Program: U.S. Department of Agriculture ? Water & Waste Disposal Systems for Rural Communities (AL #10.760) Questioned Costs: No costs have been questioned as a result of this finding. Criteria: The Code of Federal Regulations (CFR) Section 200.303(b) requires non-Federal entities to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and terms and conditions of the Federal award. CFR Section 200.502(a) states that the determination of when a Federal award is expended should be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as expenditure/expense transactions associated with grant awards. The City reports expenditures on the SEFA when the expenditure has been incurred, or on the accrual basis of accounting, in accordance with generally accepted accounting principles. CFR Section 200.510(b) requires the auditee to prepare a SEFA for the period covered by the auditee?s financial statements which must include the total Federal awards expended as determined in accordance with CFR Section 200.502(a), as stated above, and must reconcile amounts reported in the SEFA to the amounts reported in the auditee?s financial statements. Condition: The SEFA was not appropriately reconciled to federal grant revenues and expenditures recorded in the financial statements. Changes were made to major program expenditures, as well as expenditures of other programs, during the closing process and during the completion of the single audit to properly report expenditures on the SEFA. Closing procedures should be in place to reconcile grant expenditures incurred at year-end, confirm the amount as eligible with the grantor, claim the grant revenues on a timely basis, reconcile the claim to the general ledger, and ensure the expenditures that will be claimed under federal awards are properly reported on the SEFA and audited financial statements prior to the start of the single audit. If expenditures reported on the SEFA are misstated, the City could fail to have a program appropriately identified as a major program and tested as a major program during the single audit. Failure to have a program audited during the single audit would result in noncompliance with Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Cause: Closing procedures were not in place and management did not effectively communicate with City departments and consultants responsible for administering federal awards to identify all federal grant related activity. Effect: The SEFA required material adjustments to include all federal expenditures prior to the single audit beginning, which resulted in a misstated preliminary SEFA and inefficiencies during the single audit. Recommendation: We recommend that management meet with department heads and third party consultants throughout the year and during the closing process to identify all expenditures under federal awards. Training should be provided to all staff to make sure they are aware of the importance of accurately reconciling and claiming grant expenditures on a timely basis and providing the information to management for inclusion on the SEFA. Management Response: The City will work to improve closing processes and communications with various departments and consultants to ensure the SEFA is complete and accurate.
2022-005 ? Material Weakness and Noncompliance: Preparation of Schedule of Expenditures of Federal Awards (SEFA) Finding Type: Material Weakness in Internal Controls and Noncompliance (Reporting and Allowable Costs/Cost Principles) Federal Program: U.S. Department of Agriculture ? Water & Waste Disposal Systems for Rural Communities (AL #10.760) Questioned Costs: No costs have been questioned as a result of this finding. Criteria: The Code of Federal Regulations (CFR) Section 200.303(b) requires non-Federal entities to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and terms and conditions of the Federal award. CFR Section 200.502(a) states that the determination of when a Federal award is expended should be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as expenditure/expense transactions associated with grant awards. The City reports expenditures on the SEFA when the expenditure has been incurred, or on the accrual basis of accounting, in accordance with generally accepted accounting principles. CFR Section 200.510(b) requires the auditee to prepare a SEFA for the period covered by the auditee?s financial statements which must include the total Federal awards expended as determined in accordance with CFR Section 200.502(a), as stated above, and must reconcile amounts reported in the SEFA to the amounts reported in the auditee?s financial statements. Condition: The SEFA was not appropriately reconciled to federal grant revenues and expenditures recorded in the financial statements. Changes were made to major program expenditures, as well as expenditures of other programs, during the closing process and during the completion of the single audit to properly report expenditures on the SEFA. Closing procedures should be in place to reconcile grant expenditures incurred at year-end, confirm the amount as eligible with the grantor, claim the grant revenues on a timely basis, reconcile the claim to the general ledger, and ensure the expenditures that will be claimed under federal awards are properly reported on the SEFA and audited financial statements prior to the start of the single audit. If expenditures reported on the SEFA are misstated, the City could fail to have a program appropriately identified as a major program and tested as a major program during the single audit. Failure to have a program audited during the single audit would result in noncompliance with Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Cause: Closing procedures were not in place and management did not effectively communicate with City departments and consultants responsible for administering federal awards to identify all federal grant related activity. Effect: The SEFA required material adjustments to include all federal expenditures prior to the single audit beginning, which resulted in a misstated preliminary SEFA and inefficiencies during the single audit. Recommendation: We recommend that management meet with department heads and third party consultants throughout the year and during the closing process to identify all expenditures under federal awards. Training should be provided to all staff to make sure they are aware of the importance of accurately reconciling and claiming grant expenditures on a timely basis and providing the information to management for inclusion on the SEFA. Management Response: The City will work to improve closing processes and communications with various departments and consultants to ensure the SEFA is complete and accurate.
2022-005 ? Material Weakness and Noncompliance: Preparation of Schedule of Expenditures of Federal Awards (SEFA) Finding Type: Material Weakness in Internal Controls and Noncompliance (Reporting and Allowable Costs/Cost Principles) Federal Program: U.S. Department of Agriculture ? Water & Waste Disposal Systems for Rural Communities (AL #10.760) Questioned Costs: No costs have been questioned as a result of this finding. Criteria: The Code of Federal Regulations (CFR) Section 200.303(b) requires non-Federal entities to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and terms and conditions of the Federal award. CFR Section 200.502(a) states that the determination of when a Federal award is expended should be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as expenditure/expense transactions associated with grant awards. The City reports expenditures on the SEFA when the expenditure has been incurred, or on the accrual basis of accounting, in accordance with generally accepted accounting principles. CFR Section 200.510(b) requires the auditee to prepare a SEFA for the period covered by the auditee?s financial statements which must include the total Federal awards expended as determined in accordance with CFR Section 200.502(a), as stated above, and must reconcile amounts reported in the SEFA to the amounts reported in the auditee?s financial statements. Condition: The SEFA was not appropriately reconciled to federal grant revenues and expenditures recorded in the financial statements. Changes were made to major program expenditures, as well as expenditures of other programs, during the closing process and during the completion of the single audit to properly report expenditures on the SEFA. Closing procedures should be in place to reconcile grant expenditures incurred at year-end, confirm the amount as eligible with the grantor, claim the grant revenues on a timely basis, reconcile the claim to the general ledger, and ensure the expenditures that will be claimed under federal awards are properly reported on the SEFA and audited financial statements prior to the start of the single audit. If expenditures reported on the SEFA are misstated, the City could fail to have a program appropriately identified as a major program and tested as a major program during the single audit. Failure to have a program audited during the single audit would result in noncompliance with Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Cause: Closing procedures were not in place and management did not effectively communicate with City departments and consultants responsible for administering federal awards to identify all federal grant related activity. Effect: The SEFA required material adjustments to include all federal expenditures prior to the single audit beginning, which resulted in a misstated preliminary SEFA and inefficiencies during the single audit. Recommendation: We recommend that management meet with department heads and third party consultants throughout the year and during the closing process to identify all expenditures under federal awards. Training should be provided to all staff to make sure they are aware of the importance of accurately reconciling and claiming grant expenditures on a timely basis and providing the information to management for inclusion on the SEFA. Management Response: The City will work to improve closing processes and communications with various departments and consultants to ensure the SEFA is complete and accurate.
2022-005 ? Material Weakness and Noncompliance: Preparation of Schedule of Expenditures of Federal Awards (SEFA) Finding Type: Material Weakness in Internal Controls and Noncompliance (Reporting and Allowable Costs/Cost Principles) Federal Program: U.S. Department of Agriculture ? Water & Waste Disposal Systems for Rural Communities (AL #10.760) Questioned Costs: No costs have been questioned as a result of this finding. Criteria: The Code of Federal Regulations (CFR) Section 200.303(b) requires non-Federal entities to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and terms and conditions of the Federal award. CFR Section 200.502(a) states that the determination of when a Federal award is expended should be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as expenditure/expense transactions associated with grant awards. The City reports expenditures on the SEFA when the expenditure has been incurred, or on the accrual basis of accounting, in accordance with generally accepted accounting principles. CFR Section 200.510(b) requires the auditee to prepare a SEFA for the period covered by the auditee?s financial statements which must include the total Federal awards expended as determined in accordance with CFR Section 200.502(a), as stated above, and must reconcile amounts reported in the SEFA to the amounts reported in the auditee?s financial statements. Condition: The SEFA was not appropriately reconciled to federal grant revenues and expenditures recorded in the financial statements. Changes were made to major program expenditures, as well as expenditures of other programs, during the closing process and during the completion of the single audit to properly report expenditures on the SEFA. Closing procedures should be in place to reconcile grant expenditures incurred at year-end, confirm the amount as eligible with the grantor, claim the grant revenues on a timely basis, reconcile the claim to the general ledger, and ensure the expenditures that will be claimed under federal awards are properly reported on the SEFA and audited financial statements prior to the start of the single audit. If expenditures reported on the SEFA are misstated, the City could fail to have a program appropriately identified as a major program and tested as a major program during the single audit. Failure to have a program audited during the single audit would result in noncompliance with Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Cause: Closing procedures were not in place and management did not effectively communicate with City departments and consultants responsible for administering federal awards to identify all federal grant related activity. Effect: The SEFA required material adjustments to include all federal expenditures prior to the single audit beginning, which resulted in a misstated preliminary SEFA and inefficiencies during the single audit. Recommendation: We recommend that management meet with department heads and third party consultants throughout the year and during the closing process to identify all expenditures under federal awards. Training should be provided to all staff to make sure they are aware of the importance of accurately reconciling and claiming grant expenditures on a timely basis and providing the information to management for inclusion on the SEFA. Management Response: The City will work to improve closing processes and communications with various departments and consultants to ensure the SEFA is complete and accurate.
Finding No. 2022-001 Federal Agency: U.S. Department of Health and Human Services Program Name: HRSA COVID-19 Claims Reimbursement for the Uninsured Program and the COVID-19 Coverage Assistance Fund Assistance Listing Number: 93.461 Federal Award Year: July 1, 2021 ? June 30, 2022 Compliance Requirements: Other ? Inaccurate reporting of the Schedule of Expenditures of Federal Awards Criteria According to 2 CFR 200.510(b), a recipient of federal awards is required to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the entity?s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR 200.502. Additionally, 2 CFR 200.303 requires non-Federal entities receiving Federal awards to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure federal expenditures are accurately reported on the SEFA and information provided for audit purposes is complete and accurate. Conditions Found Lehigh Valley Health Network and Subsidiaries (the ?Organization?) did not have adequate controls relating to the reporting of expenditures for the HRSA COVID-19 Claims Reimbursement for the Uninsured Program and the COVID-19 Coverage Assistance Fund (the ?Uninsured Program?) in the SEFA. Specifically, the amounts originally provided on the SEFA for the year ended June 30, 2022 for the Uninsured Program were based on when claim payments were received rather than when the services were provided for claim reimbursement. Once the error was identified, management corrected the SEFA for the year ended June 30, 2022 to reflect the total amount of claims for services provided during the year ended June 30, 2022 for the Uninsured Program. Cause and Effect In discussing these conditions with management, they stated that sufficient controls were not in place to ensure that the date of the patient service or treatment was used to determine the appropriate amounts and year to include the payment received from HRSA on the SEFA. Failure to establish effective internal controls regarding financial reporting for the preparation of the SEFA may prevent the Organization from completing an audit in accordance with 2 CFR Part 200. Questioned Costs There are no questioned costs related to this finding. Statistical Sample Not applicable. Repeat Finding A similar finding was not reported in the prior year audit. Recommendation We recommend the Organization establish internal controls to ensure the HRSA COVID-19 Uninsured Program is accurately reported on the SEFA and information provided for audit purposes is complete and accurate. View of Responsible Officials Since the inception of the program, the Organization reported the HRSA COVID-19 for the Uninsured based on payment date rather than on date of service/ incurred date. Once the error was identified, management properly reported and corrected the SEFA for the year ended June 30, 2022 to reflect the total amount of claims for services provided during the year ended June 30, 2022 for the Uninsured Program.
Finding No. 2022-001 Federal Agency: U.S. Department of Health and Human Services Program Name: HRSA COVID-19 Claims Reimbursement for the Uninsured Program and the COVID-19 Coverage Assistance Fund Assistance Listing Number: 93.461 Federal Award Year: July 1, 2021 ? June 30, 2022 Compliance Requirements: Other ? Inaccurate reporting of the Schedule of Expenditures of Federal Awards Criteria According to 2 CFR 200.510(b), a recipient of federal awards is required to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the entity?s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR 200.502. Additionally, 2 CFR 200.303 requires non-Federal entities receiving Federal awards to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure federal expenditures are accurately reported on the SEFA and information provided for audit purposes is complete and accurate. Conditions Found Lehigh Valley Health Network and Subsidiaries (the ?Organization?) did not have adequate controls relating to the reporting of expenditures for the HRSA COVID-19 Claims Reimbursement for the Uninsured Program and the COVID-19 Coverage Assistance Fund (the ?Uninsured Program?) in the SEFA. Specifically, the amounts originally provided on the SEFA for the year ended June 30, 2022 for the Uninsured Program were based on when claim payments were received rather than when the services were provided for claim reimbursement. Once the error was identified, management corrected the SEFA for the year ended June 30, 2022 to reflect the total amount of claims for services provided during the year ended June 30, 2022 for the Uninsured Program. Cause and Effect In discussing these conditions with management, they stated that sufficient controls were not in place to ensure that the date of the patient service or treatment was used to determine the appropriate amounts and year to include the payment received from HRSA on the SEFA. Failure to establish effective internal controls regarding financial reporting for the preparation of the SEFA may prevent the Organization from completing an audit in accordance with 2 CFR Part 200. Questioned Costs There are no questioned costs related to this finding. Statistical Sample Not applicable. Repeat Finding A similar finding was not reported in the prior year audit. Recommendation We recommend the Organization establish internal controls to ensure the HRSA COVID-19 Uninsured Program is accurately reported on the SEFA and information provided for audit purposes is complete and accurate. View of Responsible Officials Since the inception of the program, the Organization reported the HRSA COVID-19 for the Uninsured based on payment date rather than on date of service/ incurred date. Once the error was identified, management properly reported and corrected the SEFA for the year ended June 30, 2022 to reflect the total amount of claims for services provided during the year ended June 30, 2022 for the Uninsured Program.
Finding No. 2022-001 Federal Agency: U.S. Department of Health and Human Services Program Name: HRSA COVID-19 Claims Reimbursement for the Uninsured Program and the COVID-19 Coverage Assistance Fund Assistance Listing Number: 93.461 Federal Award Year: July 1, 2021 ? June 30, 2022 Compliance Requirements: Other ? Inaccurate reporting of the Schedule of Expenditures of Federal Awards Criteria According to 2 CFR 200.510(b), a recipient of federal awards is required to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the entity?s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR 200.502. Additionally, 2 CFR 200.303 requires non-Federal entities receiving Federal awards to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure federal expenditures are accurately reported on the SEFA and information provided for audit purposes is complete and accurate. Conditions Found Lehigh Valley Health Network and Subsidiaries (the ?Organization?) did not have adequate controls relating to the reporting of expenditures for the HRSA COVID-19 Claims Reimbursement for the Uninsured Program and the COVID-19 Coverage Assistance Fund (the ?Uninsured Program?) in the SEFA. Specifically, the amounts originally provided on the SEFA for the year ended June 30, 2022 for the Uninsured Program were based on when claim payments were received rather than when the services were provided for claim reimbursement. Once the error was identified, management corrected the SEFA for the year ended June 30, 2022 to reflect the total amount of claims for services provided during the year ended June 30, 2022 for the Uninsured Program. Cause and Effect In discussing these conditions with management, they stated that sufficient controls were not in place to ensure that the date of the patient service or treatment was used to determine the appropriate amounts and year to include the payment received from HRSA on the SEFA. Failure to establish effective internal controls regarding financial reporting for the preparation of the SEFA may prevent the Organization from completing an audit in accordance with 2 CFR Part 200. Questioned Costs There are no questioned costs related to this finding. Statistical Sample Not applicable. Repeat Finding A similar finding was not reported in the prior year audit. Recommendation We recommend the Organization establish internal controls to ensure the HRSA COVID-19 Uninsured Program is accurately reported on the SEFA and information provided for audit purposes is complete and accurate. View of Responsible Officials Since the inception of the program, the Organization reported the HRSA COVID-19 for the Uninsured based on payment date rather than on date of service/ incurred date. Once the error was identified, management properly reported and corrected the SEFA for the year ended June 30, 2022 to reflect the total amount of claims for services provided during the year ended June 30, 2022 for the Uninsured Program.
Finding No. 2022-001 Federal Agency: U.S. Department of Health and Human Services Program Name: HRSA COVID-19 Claims Reimbursement for the Uninsured Program and the COVID-19 Coverage Assistance Fund Assistance Listing Number: 93.461 Federal Award Year: July 1, 2021 ? June 30, 2022 Compliance Requirements: Other ? Inaccurate reporting of the Schedule of Expenditures of Federal Awards Criteria According to 2 CFR 200.510(b), a recipient of federal awards is required to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the entity?s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR 200.502. Additionally, 2 CFR 200.303 requires non-Federal entities receiving Federal awards to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure federal expenditures are accurately reported on the SEFA and information provided for audit purposes is complete and accurate. Conditions Found Lehigh Valley Health Network and Subsidiaries (the ?Organization?) did not have adequate controls relating to the reporting of expenditures for the HRSA COVID-19 Claims Reimbursement for the Uninsured Program and the COVID-19 Coverage Assistance Fund (the ?Uninsured Program?) in the SEFA. Specifically, the amounts originally provided on the SEFA for the year ended June 30, 2022 for the Uninsured Program were based on when claim payments were received rather than when the services were provided for claim reimbursement. Once the error was identified, management corrected the SEFA for the year ended June 30, 2022 to reflect the total amount of claims for services provided during the year ended June 30, 2022 for the Uninsured Program. Cause and Effect In discussing these conditions with management, they stated that sufficient controls were not in place to ensure that the date of the patient service or treatment was used to determine the appropriate amounts and year to include the payment received from HRSA on the SEFA. Failure to establish effective internal controls regarding financial reporting for the preparation of the SEFA may prevent the Organization from completing an audit in accordance with 2 CFR Part 200. Questioned Costs There are no questioned costs related to this finding. Statistical Sample Not applicable. Repeat Finding A similar finding was not reported in the prior year audit. Recommendation We recommend the Organization establish internal controls to ensure the HRSA COVID-19 Uninsured Program is accurately reported on the SEFA and information provided for audit purposes is complete and accurate. View of Responsible Officials Since the inception of the program, the Organization reported the HRSA COVID-19 for the Uninsured based on payment date rather than on date of service/ incurred date. Once the error was identified, management properly reported and corrected the SEFA for the year ended June 30, 2022 to reflect the total amount of claims for services provided during the year ended June 30, 2022 for the Uninsured Program.
Finding No. 2022-001 Federal Agency: U.S. Department of Health and Human Services Program Name: HRSA COVID-19 Claims Reimbursement for the Uninsured Program and the COVID-19 Coverage Assistance Fund Assistance Listing Number: 93.461 Federal Award Year: July 1, 2021 ? June 30, 2022 Compliance Requirements: Other ? Inaccurate reporting of the Schedule of Expenditures of Federal Awards Criteria According to 2 CFR 200.510(b), a recipient of federal awards is required to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the entity?s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR 200.502. Additionally, 2 CFR 200.303 requires non-Federal entities receiving Federal awards to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure federal expenditures are accurately reported on the SEFA and information provided for audit purposes is complete and accurate. Conditions Found Lehigh Valley Health Network and Subsidiaries (the ?Organization?) did not have adequate controls relating to the reporting of expenditures for the HRSA COVID-19 Claims Reimbursement for the Uninsured Program and the COVID-19 Coverage Assistance Fund (the ?Uninsured Program?) in the SEFA. Specifically, the amounts originally provided on the SEFA for the year ended June 30, 2022 for the Uninsured Program were based on when claim payments were received rather than when the services were provided for claim reimbursement. Once the error was identified, management corrected the SEFA for the year ended June 30, 2022 to reflect the total amount of claims for services provided during the year ended June 30, 2022 for the Uninsured Program. Cause and Effect In discussing these conditions with management, they stated that sufficient controls were not in place to ensure that the date of the patient service or treatment was used to determine the appropriate amounts and year to include the payment received from HRSA on the SEFA. Failure to establish effective internal controls regarding financial reporting for the preparation of the SEFA may prevent the Organization from completing an audit in accordance with 2 CFR Part 200. Questioned Costs There are no questioned costs related to this finding. Statistical Sample Not applicable. Repeat Finding A similar finding was not reported in the prior year audit. Recommendation We recommend the Organization establish internal controls to ensure the HRSA COVID-19 Uninsured Program is accurately reported on the SEFA and information provided for audit purposes is complete and accurate. View of Responsible Officials Since the inception of the program, the Organization reported the HRSA COVID-19 for the Uninsured based on payment date rather than on date of service/ incurred date. Once the error was identified, management properly reported and corrected the SEFA for the year ended June 30, 2022 to reflect the total amount of claims for services provided during the year ended June 30, 2022 for the Uninsured Program.
Finding No. 2022-001 Federal Agency: U.S. Department of Health and Human Services Program Name: HRSA COVID-19 Claims Reimbursement for the Uninsured Program and the COVID-19 Coverage Assistance Fund Assistance Listing Number: 93.461 Federal Award Year: July 1, 2021 ? June 30, 2022 Compliance Requirements: Other ? Inaccurate reporting of the Schedule of Expenditures of Federal Awards Criteria According to 2 CFR 200.510(b), a recipient of federal awards is required to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the entity?s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR 200.502. Additionally, 2 CFR 200.303 requires non-Federal entities receiving Federal awards to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure federal expenditures are accurately reported on the SEFA and information provided for audit purposes is complete and accurate. Conditions Found Lehigh Valley Health Network and Subsidiaries (the ?Organization?) did not have adequate controls relating to the reporting of expenditures for the HRSA COVID-19 Claims Reimbursement for the Uninsured Program and the COVID-19 Coverage Assistance Fund (the ?Uninsured Program?) in the SEFA. Specifically, the amounts originally provided on the SEFA for the year ended June 30, 2022 for the Uninsured Program were based on when claim payments were received rather than when the services were provided for claim reimbursement. Once the error was identified, management corrected the SEFA for the year ended June 30, 2022 to reflect the total amount of claims for services provided during the year ended June 30, 2022 for the Uninsured Program. Cause and Effect In discussing these conditions with management, they stated that sufficient controls were not in place to ensure that the date of the patient service or treatment was used to determine the appropriate amounts and year to include the payment received from HRSA on the SEFA. Failure to establish effective internal controls regarding financial reporting for the preparation of the SEFA may prevent the Organization from completing an audit in accordance with 2 CFR Part 200. Questioned Costs There are no questioned costs related to this finding. Statistical Sample Not applicable. Repeat Finding A similar finding was not reported in the prior year audit. Recommendation We recommend the Organization establish internal controls to ensure the HRSA COVID-19 Uninsured Program is accurately reported on the SEFA and information provided for audit purposes is complete and accurate. View of Responsible Officials Since the inception of the program, the Organization reported the HRSA COVID-19 for the Uninsured based on payment date rather than on date of service/ incurred date. Once the error was identified, management properly reported and corrected the SEFA for the year ended June 30, 2022 to reflect the total amount of claims for services provided during the year ended June 30, 2022 for the Uninsured Program.
Finding No. 2022-001 Federal Agency: U.S. Department of Health and Human Services Program Name: HRSA COVID-19 Claims Reimbursement for the Uninsured Program and the COVID-19 Coverage Assistance Fund Assistance Listing Number: 93.461 Federal Award Year: July 1, 2021 ? June 30, 2022 Compliance Requirements: Other ? Inaccurate reporting of the Schedule of Expenditures of Federal Awards Criteria According to 2 CFR 200.510(b), a recipient of federal awards is required to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the entity?s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR 200.502. Additionally, 2 CFR 200.303 requires non-Federal entities receiving Federal awards to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure federal expenditures are accurately reported on the SEFA and information provided for audit purposes is complete and accurate. Conditions Found Lehigh Valley Health Network and Subsidiaries (the ?Organization?) did not have adequate controls relating to the reporting of expenditures for the HRSA COVID-19 Claims Reimbursement for the Uninsured Program and the COVID-19 Coverage Assistance Fund (the ?Uninsured Program?) in the SEFA. Specifically, the amounts originally provided on the SEFA for the year ended June 30, 2022 for the Uninsured Program were based on when claim payments were received rather than when the services were provided for claim reimbursement. Once the error was identified, management corrected the SEFA for the year ended June 30, 2022 to reflect the total amount of claims for services provided during the year ended June 30, 2022 for the Uninsured Program. Cause and Effect In discussing these conditions with management, they stated that sufficient controls were not in place to ensure that the date of the patient service or treatment was used to determine the appropriate amounts and year to include the payment received from HRSA on the SEFA. Failure to establish effective internal controls regarding financial reporting for the preparation of the SEFA may prevent the Organization from completing an audit in accordance with 2 CFR Part 200. Questioned Costs There are no questioned costs related to this finding. Statistical Sample Not applicable. Repeat Finding A similar finding was not reported in the prior year audit. Recommendation We recommend the Organization establish internal controls to ensure the HRSA COVID-19 Uninsured Program is accurately reported on the SEFA and information provided for audit purposes is complete and accurate. View of Responsible Officials Since the inception of the program, the Organization reported the HRSA COVID-19 for the Uninsured based on payment date rather than on date of service/ incurred date. Once the error was identified, management properly reported and corrected the SEFA for the year ended June 30, 2022 to reflect the total amount of claims for services provided during the year ended June 30, 2022 for the Uninsured Program.
Finding No. 2022-001 Federal Agency: U.S. Department of Health and Human Services Program Name: HRSA COVID-19 Claims Reimbursement for the Uninsured Program and the COVID-19 Coverage Assistance Fund Assistance Listing Number: 93.461 Federal Award Year: July 1, 2021 ? June 30, 2022 Compliance Requirements: Other ? Inaccurate reporting of the Schedule of Expenditures of Federal Awards Criteria According to 2 CFR 200.510(b), a recipient of federal awards is required to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the entity?s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR 200.502. Additionally, 2 CFR 200.303 requires non-Federal entities receiving Federal awards to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure federal expenditures are accurately reported on the SEFA and information provided for audit purposes is complete and accurate. Conditions Found Lehigh Valley Health Network and Subsidiaries (the ?Organization?) did not have adequate controls relating to the reporting of expenditures for the HRSA COVID-19 Claims Reimbursement for the Uninsured Program and the COVID-19 Coverage Assistance Fund (the ?Uninsured Program?) in the SEFA. Specifically, the amounts originally provided on the SEFA for the year ended June 30, 2022 for the Uninsured Program were based on when claim payments were received rather than when the services were provided for claim reimbursement. Once the error was identified, management corrected the SEFA for the year ended June 30, 2022 to reflect the total amount of claims for services provided during the year ended June 30, 2022 for the Uninsured Program. Cause and Effect In discussing these conditions with management, they stated that sufficient controls were not in place to ensure that the date of the patient service or treatment was used to determine the appropriate amounts and year to include the payment received from HRSA on the SEFA. Failure to establish effective internal controls regarding financial reporting for the preparation of the SEFA may prevent the Organization from completing an audit in accordance with 2 CFR Part 200. Questioned Costs There are no questioned costs related to this finding. Statistical Sample Not applicable. Repeat Finding A similar finding was not reported in the prior year audit. Recommendation We recommend the Organization establish internal controls to ensure the HRSA COVID-19 Uninsured Program is accurately reported on the SEFA and information provided for audit purposes is complete and accurate. View of Responsible Officials Since the inception of the program, the Organization reported the HRSA COVID-19 for the Uninsured based on payment date rather than on date of service/ incurred date. Once the error was identified, management properly reported and corrected the SEFA for the year ended June 30, 2022 to reflect the total amount of claims for services provided during the year ended June 30, 2022 for the Uninsured Program.
Finding No. 2022-001 Federal Agency: U.S. Department of Health and Human Services Program Name: HRSA COVID-19 Claims Reimbursement for the Uninsured Program and the COVID-19 Coverage Assistance Fund Assistance Listing Number: 93.461 Federal Award Year: July 1, 2021 ? June 30, 2022 Compliance Requirements: Other ? Inaccurate reporting of the Schedule of Expenditures of Federal Awards Criteria According to 2 CFR 200.510(b), a recipient of federal awards is required to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the entity?s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR 200.502. Additionally, 2 CFR 200.303 requires non-Federal entities receiving Federal awards to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure federal expenditures are accurately reported on the SEFA and information provided for audit purposes is complete and accurate. Conditions Found Lehigh Valley Health Network and Subsidiaries (the ?Organization?) did not have adequate controls relating to the reporting of expenditures for the HRSA COVID-19 Claims Reimbursement for the Uninsured Program and the COVID-19 Coverage Assistance Fund (the ?Uninsured Program?) in the SEFA. Specifically, the amounts originally provided on the SEFA for the year ended June 30, 2022 for the Uninsured Program were based on when claim payments were received rather than when the services were provided for claim reimbursement. Once the error was identified, management corrected the SEFA for the year ended June 30, 2022 to reflect the total amount of claims for services provided during the year ended June 30, 2022 for the Uninsured Program. Cause and Effect In discussing these conditions with management, they stated that sufficient controls were not in place to ensure that the date of the patient service or treatment was used to determine the appropriate amounts and year to include the payment received from HRSA on the SEFA. Failure to establish effective internal controls regarding financial reporting for the preparation of the SEFA may prevent the Organization from completing an audit in accordance with 2 CFR Part 200. Questioned Costs There are no questioned costs related to this finding. Statistical Sample Not applicable. Repeat Finding A similar finding was not reported in the prior year audit. Recommendation We recommend the Organization establish internal controls to ensure the HRSA COVID-19 Uninsured Program is accurately reported on the SEFA and information provided for audit purposes is complete and accurate. View of Responsible Officials Since the inception of the program, the Organization reported the HRSA COVID-19 for the Uninsured based on payment date rather than on date of service/ incurred date. Once the error was identified, management properly reported and corrected the SEFA for the year ended June 30, 2022 to reflect the total amount of claims for services provided during the year ended June 30, 2022 for the Uninsured Program.
Finding No. 2022-001 Federal Agency: U.S. Department of Health and Human Services Program Name: HRSA COVID-19 Claims Reimbursement for the Uninsured Program and the COVID-19 Coverage Assistance Fund Assistance Listing Number: 93.461 Federal Award Year: July 1, 2021 ? June 30, 2022 Compliance Requirements: Other ? Inaccurate reporting of the Schedule of Expenditures of Federal Awards Criteria According to 2 CFR 200.510(b), a recipient of federal awards is required to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the entity?s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR 200.502. Additionally, 2 CFR 200.303 requires non-Federal entities receiving Federal awards to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure federal expenditures are accurately reported on the SEFA and information provided for audit purposes is complete and accurate. Conditions Found Lehigh Valley Health Network and Subsidiaries (the ?Organization?) did not have adequate controls relating to the reporting of expenditures for the HRSA COVID-19 Claims Reimbursement for the Uninsured Program and the COVID-19 Coverage Assistance Fund (the ?Uninsured Program?) in the SEFA. Specifically, the amounts originally provided on the SEFA for the year ended June 30, 2022 for the Uninsured Program were based on when claim payments were received rather than when the services were provided for claim reimbursement. Once the error was identified, management corrected the SEFA for the year ended June 30, 2022 to reflect the total amount of claims for services provided during the year ended June 30, 2022 for the Uninsured Program. Cause and Effect In discussing these conditions with management, they stated that sufficient controls were not in place to ensure that the date of the patient service or treatment was used to determine the appropriate amounts and year to include the payment received from HRSA on the SEFA. Failure to establish effective internal controls regarding financial reporting for the preparation of the SEFA may prevent the Organization from completing an audit in accordance with 2 CFR Part 200. Questioned Costs There are no questioned costs related to this finding. Statistical Sample Not applicable. Repeat Finding A similar finding was not reported in the prior year audit. Recommendation We recommend the Organization establish internal controls to ensure the HRSA COVID-19 Uninsured Program is accurately reported on the SEFA and information provided for audit purposes is complete and accurate. View of Responsible Officials Since the inception of the program, the Organization reported the HRSA COVID-19 for the Uninsured based on payment date rather than on date of service/ incurred date. Once the error was identified, management properly reported and corrected the SEFA for the year ended June 30, 2022 to reflect the total amount of claims for services provided during the year ended June 30, 2022 for the Uninsured Program.
Finding No. 2022-001 Federal Agency: U.S. Department of Health and Human Services Program Name: HRSA COVID-19 Claims Reimbursement for the Uninsured Program and the COVID-19 Coverage Assistance Fund Assistance Listing Number: 93.461 Federal Award Year: July 1, 2021 ? June 30, 2022 Compliance Requirements: Other ? Inaccurate reporting of the Schedule of Expenditures of Federal Awards Criteria According to 2 CFR 200.510(b), a recipient of federal awards is required to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the entity?s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR 200.502. Additionally, 2 CFR 200.303 requires non-Federal entities receiving Federal awards to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure federal expenditures are accurately reported on the SEFA and information provided for audit purposes is complete and accurate. Conditions Found Lehigh Valley Health Network and Subsidiaries (the ?Organization?) did not have adequate controls relating to the reporting of expenditures for the HRSA COVID-19 Claims Reimbursement for the Uninsured Program and the COVID-19 Coverage Assistance Fund (the ?Uninsured Program?) in the SEFA. Specifically, the amounts originally provided on the SEFA for the year ended June 30, 2022 for the Uninsured Program were based on when claim payments were received rather than when the services were provided for claim reimbursement. Once the error was identified, management corrected the SEFA for the year ended June 30, 2022 to reflect the total amount of claims for services provided during the year ended June 30, 2022 for the Uninsured Program. Cause and Effect In discussing these conditions with management, they stated that sufficient controls were not in place to ensure that the date of the patient service or treatment was used to determine the appropriate amounts and year to include the payment received from HRSA on the SEFA. Failure to establish effective internal controls regarding financial reporting for the preparation of the SEFA may prevent the Organization from completing an audit in accordance with 2 CFR Part 200. Questioned Costs There are no questioned costs related to this finding. Statistical Sample Not applicable. Repeat Finding A similar finding was not reported in the prior year audit. Recommendation We recommend the Organization establish internal controls to ensure the HRSA COVID-19 Uninsured Program is accurately reported on the SEFA and information provided for audit purposes is complete and accurate. View of Responsible Officials Since the inception of the program, the Organization reported the HRSA COVID-19 for the Uninsured based on payment date rather than on date of service/ incurred date. Once the error was identified, management properly reported and corrected the SEFA for the year ended June 30, 2022 to reflect the total amount of claims for services provided during the year ended June 30, 2022 for the Uninsured Program.
2022 002 Assistance Listing Number, Federal Agency, and Program Name 93.498, Department of Health and Human Services, Provider Relief Fund and American Rescue Plan Rural Distribution Federal Award Identification Number and Year N/A Pass through Entity N/A Finding Type Significant deficiency Repeat Finding No Criteria Per 2 CFR 200.508(b), an auditee must prepare appropriate financial statements, including the schedule of expenditures of federal awards, in accordance with 200.510 financial statements. Per 2 CFR 200.510(b), the auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended, as determined in accordance with 200.502 basis for determining federal awards expended. Additionally, per the frequently asked questions published by HRSA, and in conjunction with the compliance supplement issued by the office of management and budget, recipients with fiscal year ends of June 30, 2021 should report the total expenditures from the Period 1 provider relief fund portal submission on the SEFA. Condition The Corporation did not prepare a complete and accurate SEFA for the year ended June 30, 2021. Questioned Costs N/A Identification of How Questioned Costs Were Computed N/A Context The Corporation's SEFA was understated for the year ended June 30, 2021 by $1,271,104. Management has acknowledged the SEFA was understated for 2021. The SEFA for June 30, 2022 is complete and accurate. Cause and Effect Management of the Corporation misunderstood guidance regarding preparation of the SEFA for the year ended June 30, 2021, resulting in the SEFA being incomplete for the year ended June 30, 2021. The $1,271,104 of funds not reported on the 2021 SEFA have been included on the SEFA for the year ended June 30, 2022. Recommendation Management should continue to monitor the SEFA reporting requirements issued by OMB and ensure all federal funding received is properly included on the SEFA in the proper period. Views of Responsible Officials and Corrective Action Plan While technically considered a significant deficiency and audit finding in accordance with CFR guidance for federal award audit compliance purposes, management considers this finding to be an isolated incident. Management had prepared and provided a SEFA summary that properly identified all federal funding, including all of the CARES Act funding, received as of June 30, 2021. Management also prepared and provided information regarding amounts of the CARES Act funding expended and recognized as revenue within the financial statements for the years ended June 30, 2020 and 2021. However, there was interpretation that the amount that was supposed to be reported for the CARES Act funding on the SEFA for the period ended June 30, 2021, should be the amount expended and recognized as revenue as of the financial statements ended June 30, 2020, to align with the Period 1 portal reporting. As such, the amount reported for the final SEFA used for the June 30, 2021 compliance audit excluded $1,271,104 that was appropriately reported as deferred grant revenue liability as of June 30, 2020. The amount of CARES Act funding for the Period 1 portal reporting correctly included the $1,271,104. There was a significant amount of collective confusion regarding the Period 1 CARES Act portal reporting which was for the period ended June 30, 2020, in relation to the SEFA reporting and compliance audit reporting for that same period of time, which was unusually deferred by the federal government from June 30, 2020 to June 30, 2021. The results of the auditors procedures demonstrated that all the information management populated in the CARES Act portal for the June 30, 2020 reporting compliance Period 1 was accurate and that there were no other findings.
The following findings and recommendations relating to internal control deficiencies classified as Material Weaknesses were communicated to the Department in the previous year and have not been remediated as of June 30, 2022 because the original implementation dates provided by the Department were in a subsequent fiscal year. These complete findings and recommendations can be found within the original report and the complete recommendations can be found within Section IV: Prior Audit Recommendations of this report. See Schedule of Findings and Questioned Costs for chart/table See Schedule of Findings and Questioned Costs for footnote Finding 2021-060 Misreporting of Federal Expenditures for the COVID-19 ?Pandemic EBT Food Benefits and Child Care and Development Block Grant on the Exhibit K1 Each year, the Department is required to prepare an exhibit containing the Department?s federal expenditures and related reimbursements to aid the Colorado Office of the State Controller (OSC) in the preparation of the State?s Schedule of Expenditures of Federal Awards (SEFA); this exhibit is referred to as the Exhibit K1, Schedule of Federal Assistance. The Exhibit K1 should include expenditures for grants received directly from the federal government and expended by the Department (direct expenditures), as well as expenditures for federal grants passed through by the Department to other State and/or non-State agencies (subrecipient expenditures). The SEFA is to be presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) to show the State?s expenditures of federal awards during the fiscal year. A subrecipient is defined in federal regulations [2 CFR 200.1] as ?an entity, usually but not limited to non-Federal entities, that receives a subaward from a pass-through entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other Federal awards directly from a federal awarding agency.? Annually, the Department prepares its Exhibit K1 by following a process documented in its program accounting manual. First, program accountants review and analyze information from CORE for the federal Assistance Listing Number (ALN)?s related to the programs they support. The program accountants complete this review using a CORE report that the Department created, pulling transaction detail level data by ALN. Once the reviews and analysis are complete, the program accountants enter the information on the Department?s Exhibit K1 template for the correlating ALN. After the exhibit is prepared, the Department?s program accounting manual requires that it goes through two levels of review for accuracy. Once these reviews are completed, the Department submits the final Exhibit K1 to the OSC. The Department is also separately required within its approved State Plan for the COVID-19 ? Pandemic EBT Food Benefits program [ALN 10.542] (P-EBT) to report its P-EBT federal expenditures to the U.S. Department of Agriculture (USDA) via the Report of Disaster Food Stamp Benefit Issuance (FNS-292-B). The Department is also required to support the financial expenditures reported on the FNS-292-B report with source data and files, which includes a P-EBT Summary report that is exported from the Colorado Benefits Management System (CBMS) and includes the number of eligible children, number of eligible households, and total amount paid in P-EBT benefits. The P-EBT summary report is then reconciled by the Department to the County Financial Management System (CFMS), where the counties? issuance of P-EBT program benefits is accumulated and reported. For Fiscal Year 2021, the Department administered more than 70 federal programs and expended approximately $2.4 billion in federal funds. The P-EBT program and Child Care and Development Block Grant (Grant) [ALN 93.575] were two of these federal programs administered by the Department during Fiscal Year 2021. The Department reported more than $292 million in federal expenditures for the P-EBT program and approximately $74 million in federal expenditures for the Grant in Fiscal Year 2021. What was the purpose of our audit work and what work was performed? The purpose of our audit work was to evaluate the Department?s internal controls over the preparation of its Exhibit K1 during Fiscal Year 2021 and to determine whether the Department correctly reported its Fiscal Year 2021 federal grant expenditures to the OSC on its Exhibit K1. The purpose of our audit work was also to evaluate the Department?s internal controls over the financial reporting to the USDA regarding the P-EBT program. As part of our audit testwork, we compared amounts reported by the Department for direct and subrecipient federal expenditures on its Fiscal Year 2021 Exhibit K1 to the underlying financial records in CORE for the Grant and P-EBT federal programs and inquired about any differences. In addition, we made inquiries of Department staff regarding its internal control processes over the Exhibit K1 preparation, including supervisory reviews. We also reviewed 4 out of 12 Fiscal Year 2021 monthly submissions to the USDA for the FNS-292-B reports and compared federal expenditure amounts reported by the Department to the underlying financial records in CORE. How were the results of the audit work measured? The OSC is required to present the State?s SEFA in accordance with the federal requirements of the Uniform Guidance to show the State?s expenditures of federal awards during the fiscal year. Federal regulations [2 CFR 200.38(b)] define a federal award as, ?The instrument setting forth the terms and conditions. The instrument is the grant agreement, cooperative agreement, other agreement for assistance?? Federal regulations [2 CFR 200.510(b)(3) and (4)] require that the SEFA must show both total federal awards expended for each individual federal program, the Assistance Listing Number, and the total amount passed through to subrecipients for each federal program. In order to prepare the SEFA, the OSC requires state departments to submit an Exhibit K1 to report expenditures, receipts, and receivables for each federal grant program administered by the Department during the fiscal year. The OSC?s exhibit instructions include guidelines for completing the Exhibit K1, including defining ?direct and indirect expenditures? as ?all monetary and non-monetary direct and indirect Federal award expenditures,? and ?pass-through expenditures? as ?the amount of all monetary and non-monetary Federal award amounts passed through to a subrecipient.? For the Department?s Grant federal program, subrecipients consist of counties, school districts, and health centers. State Fiscal Rule 1-2, Internal Controls, requires that state departments ?implement internal accounting and administrative controls that reasonably ensure that financial transactions are accurate, reliable, conform to state fiscal rules, and reflect the underlying realities of the accounting transaction (substance rather than form).? Federal regulations [7 CFR 274.4] require the Department to submit an FNS-292-B report in the format prescribed by the USDA with information detailing the P-EBT federal benefit payments. The Department is required to support the information in the report with its underlying records. The FNS-292-B report is identified as a required report within the Department?s State Plan that is approved by the USDA. What problems did the audit work identify? The Department overstated $63.5 million in P-EBT expenditures on its June 2021 FNS-292-B report to USDA that was submitted on August 30, 2021, as well as on the Department?s Exhibit K1 for Fiscal Year 2021. The Department subsequently identified that the FNS-292-B report was misstated and updated and resubmitted the report on September 28, 2021, approximately one month later. The Department, however, did not update its Exhibit K1 for Fiscal Year 2021 to correct the error, because the program staff did not notify the accounting team of the misstatement and need for Exhibit K1 correction. Based on our audit testwork, we also determined that the Department misreported $8.7 million in the Grant?s expenditures as subrecipient, rather than direct, expenditures on its Exhibit K1. Why did these problems occur? The P-EBT program staff did not notify the Department?s accounting team, who prepares the Exhibit K1, of a revision to the FNS-292-B report. The P-EBT program staff prepared the reconciliation of the CBMS summary report to the CFMS P-EBT benefits issued report and identified a variance. The variance was eventually resolved and the P-EBT program staff resubmitted the FNS-292-B report to the USDA; however P-EBT program staff did not communicate this error to the Department?s accounting team. As a result, the accounting team was unaware of the revision and, therefore, did not update the Exhibit K1 to reflect the reduction in federal expenditures. Overall, the Department did not have adequate internal controls, such as an appropriate supervisory review process or adequate communication plan, in place for Fiscal Year 2021 to ensure that the FNS-292-B report was prepared accurately, that the Exhibit K1 was completed in accordance with the instructions provided by the OSC, and that the FNS-292-B and Exhibit K1 were reviewed for accuracy and compared to the underlying data. For the Grant program error, Department staff indicated that these funds were incorrectly identified and coded as subrecipient expenditures in CORE, which caused them to be incorrectly reported as such on the Exhibit K1. When the expenditures were initially posted in CORE, they were not adequately reviewed to determine if they were subrecipient or direct expenditures. Why do these problems matter? By failing to properly report grant expenditures to the federal government and the OSC, who ultimately then fails to properly report expenditures to the federal government on the State?s SEFA, the Department is out of compliance with federal and state reporting requirements and risks federal sanctions. In addition, because the error resulted in the Department misstating its federal expenditure results for the fiscal year, federal staff and taxpayers have an incorrect or unreliable picture of the P-EBT grant?s overall status. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2021-060 The Department of Human Services (Department) should strengthen its internal controls over the preparation of federal reports and the Exhibit K1, Schedule of Federal Assistance, by: A. Strengthening its internal controls over its monthly Pandemic Electronic Benefit Transfer Food Benefits (P-EBT) reporting to ensure its reporting is accurate and goes through supervisory review. B. Improving communication between program and accounting staff to ensure the Exhibit K1 is accurately updated when errors in federal reporting are identified and resolved. C. Improving the supervisory review process over the Exhibit K1 and the federal expenditures entered in the Colorado Operations Resource Engine (CORE), the state?s accounting system, to ensure expenditures are coded correctly as direct or subrecipient expenditures and that, ultimately, the Exhibit K1 is accurate and complete. Response Department of Human Services A. Agree Implementation Date: July 2022 CDHS agrees to enhance internal controls over monthly P-EBT reporting to better ensure accuracy. P-EBT is a new program derived from pandemic funding. Being a new program with a lack of federal guidance at implementation, and urgency to get the funds disbursed program staff had to learn about the nuances of the program and the reporting requirements as it was being implemented. During implementation we recognized that there are some inherent differences with P-EBT from other benefit programs which caused processes to have to be adjusted slightly. Additionally, timing of federal report filing for the P-EBT program is not in synch with our other processes and associated federal reporting requirements and deadlines. This makes it impossible to ensure reconciliation procedures are performed before filing occurs, which is one of our typical internal controls. As a compensating internal control CDHS will ensure that supervisory review processes are performed over P-EBT reporting, and that P-EBT reporting is reconciled to other sources (CBMS and CFMS) as soon as possible after reporting is available. If changes are discovered CDHS will make adjustments to filed P-EBT reports as needed based on reconciliation findings, and communicate changes to necessary parties. B. Agree Implementation Date: July 2022 CDHS will work to ensure better coordination between program activities and the accounting section relating to federal reporting changes. Accounting will iterate the importance of timely informing the accounting staff when changes are made to program filed federal reports. This message will be delivered in periodic fiscal meetings and identified on the closing calendar. The P-EBT program will ensure that corrections are communicated to accounting on any updates completed on the FNS-292-B report upon discovery, and no later than 30 days after the reporting period. C. Agree Implementation Date: July 2022 CDHS will ensure that review and approval processes are occurring as designed at various points in the process leading up to entry into CORE. As part of the Requisition (RQS) approval process program and accounting staff independently approve that the correct direct or subrecipient object code is used. These approved RQS transactions are then transitioned into encumbrance documents that drive which object code future expenditures will be booked to. For CCDF transactions related to this finding, both the OEC and Accounting teams inadvertently approved an incorrect object code in 4 RQS's. Staffing shortages coupled with a large increase in workload related to pandemic funding contributed to this oversight. To correct OEC and Accounting will train new staff, periodically familiarize themselves with the appropriate object codes, and perform quality assurance review over object codes before applying approval in CORE. The K1 is compiled from balances derived from expenditure data recorded in CORE. The compilation of the K1 relies on the fact that expenditure balances are accurate, and that prior reviews and approvals of individual transactions have occurred as designed. The K1 currently goes through various levels of review focusing on balance level validation coupled with analytical procedures. To enhance the review process, CDHS will ensure analytical procedures include line level expenditure comparison at the direct and subrecipient levels.
The following findings and recommendations relating to internal control deficiencies classified as Material Weaknesses were communicated to the Department in the previous year and have not been remediated as of June 30, 2022 because the original implementation dates provided by the Department were in a subsequent fiscal year. These complete findings and recommendations can be found within the original report and the complete recommendations can be found within Section IV: Prior Audit Recommendations of this report. See Schedule of Findings and Questioned Costs for chart/table See Schedule of Findings and Questioned Costs for footnote Finding 2021-060 Misreporting of Federal Expenditures for the COVID-19 ?Pandemic EBT Food Benefits and Child Care and Development Block Grant on the Exhibit K1 Each year, the Department is required to prepare an exhibit containing the Department?s federal expenditures and related reimbursements to aid the Colorado Office of the State Controller (OSC) in the preparation of the State?s Schedule of Expenditures of Federal Awards (SEFA); this exhibit is referred to as the Exhibit K1, Schedule of Federal Assistance. The Exhibit K1 should include expenditures for grants received directly from the federal government and expended by the Department (direct expenditures), as well as expenditures for federal grants passed through by the Department to other State and/or non-State agencies (subrecipient expenditures). The SEFA is to be presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) to show the State?s expenditures of federal awards during the fiscal year. A subrecipient is defined in federal regulations [2 CFR 200.1] as ?an entity, usually but not limited to non-Federal entities, that receives a subaward from a pass-through entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other Federal awards directly from a federal awarding agency.? Annually, the Department prepares its Exhibit K1 by following a process documented in its program accounting manual. First, program accountants review and analyze information from CORE for the federal Assistance Listing Number (ALN)?s related to the programs they support. The program accountants complete this review using a CORE report that the Department created, pulling transaction detail level data by ALN. Once the reviews and analysis are complete, the program accountants enter the information on the Department?s Exhibit K1 template for the correlating ALN. After the exhibit is prepared, the Department?s program accounting manual requires that it goes through two levels of review for accuracy. Once these reviews are completed, the Department submits the final Exhibit K1 to the OSC. The Department is also separately required within its approved State Plan for the COVID-19 ? Pandemic EBT Food Benefits program [ALN 10.542] (P-EBT) to report its P-EBT federal expenditures to the U.S. Department of Agriculture (USDA) via the Report of Disaster Food Stamp Benefit Issuance (FNS-292-B). The Department is also required to support the financial expenditures reported on the FNS-292-B report with source data and files, which includes a P-EBT Summary report that is exported from the Colorado Benefits Management System (CBMS) and includes the number of eligible children, number of eligible households, and total amount paid in P-EBT benefits. The P-EBT summary report is then reconciled by the Department to the County Financial Management System (CFMS), where the counties? issuance of P-EBT program benefits is accumulated and reported. For Fiscal Year 2021, the Department administered more than 70 federal programs and expended approximately $2.4 billion in federal funds. The P-EBT program and Child Care and Development Block Grant (Grant) [ALN 93.575] were two of these federal programs administered by the Department during Fiscal Year 2021. The Department reported more than $292 million in federal expenditures for the P-EBT program and approximately $74 million in federal expenditures for the Grant in Fiscal Year 2021. What was the purpose of our audit work and what work was performed? The purpose of our audit work was to evaluate the Department?s internal controls over the preparation of its Exhibit K1 during Fiscal Year 2021 and to determine whether the Department correctly reported its Fiscal Year 2021 federal grant expenditures to the OSC on its Exhibit K1. The purpose of our audit work was also to evaluate the Department?s internal controls over the financial reporting to the USDA regarding the P-EBT program. As part of our audit testwork, we compared amounts reported by the Department for direct and subrecipient federal expenditures on its Fiscal Year 2021 Exhibit K1 to the underlying financial records in CORE for the Grant and P-EBT federal programs and inquired about any differences. In addition, we made inquiries of Department staff regarding its internal control processes over the Exhibit K1 preparation, including supervisory reviews. We also reviewed 4 out of 12 Fiscal Year 2021 monthly submissions to the USDA for the FNS-292-B reports and compared federal expenditure amounts reported by the Department to the underlying financial records in CORE. How were the results of the audit work measured? The OSC is required to present the State?s SEFA in accordance with the federal requirements of the Uniform Guidance to show the State?s expenditures of federal awards during the fiscal year. Federal regulations [2 CFR 200.38(b)] define a federal award as, ?The instrument setting forth the terms and conditions. The instrument is the grant agreement, cooperative agreement, other agreement for assistance?? Federal regulations [2 CFR 200.510(b)(3) and (4)] require that the SEFA must show both total federal awards expended for each individual federal program, the Assistance Listing Number, and the total amount passed through to subrecipients for each federal program. In order to prepare the SEFA, the OSC requires state departments to submit an Exhibit K1 to report expenditures, receipts, and receivables for each federal grant program administered by the Department during the fiscal year. The OSC?s exhibit instructions include guidelines for completing the Exhibit K1, including defining ?direct and indirect expenditures? as ?all monetary and non-monetary direct and indirect Federal award expenditures,? and ?pass-through expenditures? as ?the amount of all monetary and non-monetary Federal award amounts passed through to a subrecipient.? For the Department?s Grant federal program, subrecipients consist of counties, school districts, and health centers. State Fiscal Rule 1-2, Internal Controls, requires that state departments ?implement internal accounting and administrative controls that reasonably ensure that financial transactions are accurate, reliable, conform to state fiscal rules, and reflect the underlying realities of the accounting transaction (substance rather than form).? Federal regulations [7 CFR 274.4] require the Department to submit an FNS-292-B report in the format prescribed by the USDA with information detailing the P-EBT federal benefit payments. The Department is required to support the information in the report with its underlying records. The FNS-292-B report is identified as a required report within the Department?s State Plan that is approved by the USDA. What problems did the audit work identify? The Department overstated $63.5 million in P-EBT expenditures on its June 2021 FNS-292-B report to USDA that was submitted on August 30, 2021, as well as on the Department?s Exhibit K1 for Fiscal Year 2021. The Department subsequently identified that the FNS-292-B report was misstated and updated and resubmitted the report on September 28, 2021, approximately one month later. The Department, however, did not update its Exhibit K1 for Fiscal Year 2021 to correct the error, because the program staff did not notify the accounting team of the misstatement and need for Exhibit K1 correction. Based on our audit testwork, we also determined that the Department misreported $8.7 million in the Grant?s expenditures as subrecipient, rather than direct, expenditures on its Exhibit K1. Why did these problems occur? The P-EBT program staff did not notify the Department?s accounting team, who prepares the Exhibit K1, of a revision to the FNS-292-B report. The P-EBT program staff prepared the reconciliation of the CBMS summary report to the CFMS P-EBT benefits issued report and identified a variance. The variance was eventually resolved and the P-EBT program staff resubmitted the FNS-292-B report to the USDA; however P-EBT program staff did not communicate this error to the Department?s accounting team. As a result, the accounting team was unaware of the revision and, therefore, did not update the Exhibit K1 to reflect the reduction in federal expenditures. Overall, the Department did not have adequate internal controls, such as an appropriate supervisory review process or adequate communication plan, in place for Fiscal Year 2021 to ensure that the FNS-292-B report was prepared accurately, that the Exhibit K1 was completed in accordance with the instructions provided by the OSC, and that the FNS-292-B and Exhibit K1 were reviewed for accuracy and compared to the underlying data. For the Grant program error, Department staff indicated that these funds were incorrectly identified and coded as subrecipient expenditures in CORE, which caused them to be incorrectly reported as such on the Exhibit K1. When the expenditures were initially posted in CORE, they were not adequately reviewed to determine if they were subrecipient or direct expenditures. Why do these problems matter? By failing to properly report grant expenditures to the federal government and the OSC, who ultimately then fails to properly report expenditures to the federal government on the State?s SEFA, the Department is out of compliance with federal and state reporting requirements and risks federal sanctions. In addition, because the error resulted in the Department misstating its federal expenditure results for the fiscal year, federal staff and taxpayers have an incorrect or unreliable picture of the P-EBT grant?s overall status. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2021-060 The Department of Human Services (Department) should strengthen its internal controls over the preparation of federal reports and the Exhibit K1, Schedule of Federal Assistance, by: A. Strengthening its internal controls over its monthly Pandemic Electronic Benefit Transfer Food Benefits (P-EBT) reporting to ensure its reporting is accurate and goes through supervisory review. B. Improving communication between program and accounting staff to ensure the Exhibit K1 is accurately updated when errors in federal reporting are identified and resolved. C. Improving the supervisory review process over the Exhibit K1 and the federal expenditures entered in the Colorado Operations Resource Engine (CORE), the state?s accounting system, to ensure expenditures are coded correctly as direct or subrecipient expenditures and that, ultimately, the Exhibit K1 is accurate and complete. Response Department of Human Services A. Agree Implementation Date: July 2022 CDHS agrees to enhance internal controls over monthly P-EBT reporting to better ensure accuracy. P-EBT is a new program derived from pandemic funding. Being a new program with a lack of federal guidance at implementation, and urgency to get the funds disbursed program staff had to learn about the nuances of the program and the reporting requirements as it was being implemented. During implementation we recognized that there are some inherent differences with P-EBT from other benefit programs which caused processes to have to be adjusted slightly. Additionally, timing of federal report filing for the P-EBT program is not in synch with our other processes and associated federal reporting requirements and deadlines. This makes it impossible to ensure reconciliation procedures are performed before filing occurs, which is one of our typical internal controls. As a compensating internal control CDHS will ensure that supervisory review processes are performed over P-EBT reporting, and that P-EBT reporting is reconciled to other sources (CBMS and CFMS) as soon as possible after reporting is available. If changes are discovered CDHS will make adjustments to filed P-EBT reports as needed based on reconciliation findings, and communicate changes to necessary parties. B. Agree Implementation Date: July 2022 CDHS will work to ensure better coordination between program activities and the accounting section relating to federal reporting changes. Accounting will iterate the importance of timely informing the accounting staff when changes are made to program filed federal reports. This message will be delivered in periodic fiscal meetings and identified on the closing calendar. The P-EBT program will ensure that corrections are communicated to accounting on any updates completed on the FNS-292-B report upon discovery, and no later than 30 days after the reporting period. C. Agree Implementation Date: July 2022 CDHS will ensure that review and approval processes are occurring as designed at various points in the process leading up to entry into CORE. As part of the Requisition (RQS) approval process program and accounting staff independently approve that the correct direct or subrecipient object code is used. These approved RQS transactions are then transitioned into encumbrance documents that drive which object code future expenditures will be booked to. For CCDF transactions related to this finding, both the OEC and Accounting teams inadvertently approved an incorrect object code in 4 RQS's. Staffing shortages coupled with a large increase in workload related to pandemic funding contributed to this oversight. To correct OEC and Accounting will train new staff, periodically familiarize themselves with the appropriate object codes, and perform quality assurance review over object codes before applying approval in CORE. The K1 is compiled from balances derived from expenditure data recorded in CORE. The compilation of the K1 relies on the fact that expenditure balances are accurate, and that prior reviews and approvals of individual transactions have occurred as designed. The K1 currently goes through various levels of review focusing on balance level validation coupled with analytical procedures. To enhance the review process, CDHS will ensure analytical procedures include line level expenditure comparison at the direct and subrecipient levels.
The following findings and recommendations relating to internal control deficiencies classified as Material Weaknesses were communicated to the Department in the previous year and have not been remediated as of June 30, 2022 because the original implementation dates provided by the Department were in a subsequent fiscal year. These complete findings and recommendations can be found within the original report and the complete recommendations can be found within Section IV: Prior Audit Recommendations of this report. See Schedule of Findings and Questioned Costs for chart/table See Schedule of Findings and Questioned Costs for footnote Finding 2021-060 Misreporting of Federal Expenditures for the COVID-19 ?Pandemic EBT Food Benefits and Child Care and Development Block Grant on the Exhibit K1 Each year, the Department is required to prepare an exhibit containing the Department?s federal expenditures and related reimbursements to aid the Colorado Office of the State Controller (OSC) in the preparation of the State?s Schedule of Expenditures of Federal Awards (SEFA); this exhibit is referred to as the Exhibit K1, Schedule of Federal Assistance. The Exhibit K1 should include expenditures for grants received directly from the federal government and expended by the Department (direct expenditures), as well as expenditures for federal grants passed through by the Department to other State and/or non-State agencies (subrecipient expenditures). The SEFA is to be presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) to show the State?s expenditures of federal awards during the fiscal year. A subrecipient is defined in federal regulations [2 CFR 200.1] as ?an entity, usually but not limited to non-Federal entities, that receives a subaward from a pass-through entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other Federal awards directly from a federal awarding agency.? Annually, the Department prepares its Exhibit K1 by following a process documented in its program accounting manual. First, program accountants review and analyze information from CORE for the federal Assistance Listing Number (ALN)?s related to the programs they support. The program accountants complete this review using a CORE report that the Department created, pulling transaction detail level data by ALN. Once the reviews and analysis are complete, the program accountants enter the information on the Department?s Exhibit K1 template for the correlating ALN. After the exhibit is prepared, the Department?s program accounting manual requires that it goes through two levels of review for accuracy. Once these reviews are completed, the Department submits the final Exhibit K1 to the OSC. The Department is also separately required within its approved State Plan for the COVID-19 ? Pandemic EBT Food Benefits program [ALN 10.542] (P-EBT) to report its P-EBT federal expenditures to the U.S. Department of Agriculture (USDA) via the Report of Disaster Food Stamp Benefit Issuance (FNS-292-B). The Department is also required to support the financial expenditures reported on the FNS-292-B report with source data and files, which includes a P-EBT Summary report that is exported from the Colorado Benefits Management System (CBMS) and includes the number of eligible children, number of eligible households, and total amount paid in P-EBT benefits. The P-EBT summary report is then reconciled by the Department to the County Financial Management System (CFMS), where the counties? issuance of P-EBT program benefits is accumulated and reported. For Fiscal Year 2021, the Department administered more than 70 federal programs and expended approximately $2.4 billion in federal funds. The P-EBT program and Child Care and Development Block Grant (Grant) [ALN 93.575] were two of these federal programs administered by the Department during Fiscal Year 2021. The Department reported more than $292 million in federal expenditures for the P-EBT program and approximately $74 million in federal expenditures for the Grant in Fiscal Year 2021. What was the purpose of our audit work and what work was performed? The purpose of our audit work was to evaluate the Department?s internal controls over the preparation of its Exhibit K1 during Fiscal Year 2021 and to determine whether the Department correctly reported its Fiscal Year 2021 federal grant expenditures to the OSC on its Exhibit K1. The purpose of our audit work was also to evaluate the Department?s internal controls over the financial reporting to the USDA regarding the P-EBT program. As part of our audit testwork, we compared amounts reported by the Department for direct and subrecipient federal expenditures on its Fiscal Year 2021 Exhibit K1 to the underlying financial records in CORE for the Grant and P-EBT federal programs and inquired about any differences. In addition, we made inquiries of Department staff regarding its internal control processes over the Exhibit K1 preparation, including supervisory reviews. We also reviewed 4 out of 12 Fiscal Year 2021 monthly submissions to the USDA for the FNS-292-B reports and compared federal expenditure amounts reported by the Department to the underlying financial records in CORE. How were the results of the audit work measured? The OSC is required to present the State?s SEFA in accordance with the federal requirements of the Uniform Guidance to show the State?s expenditures of federal awards during the fiscal year. Federal regulations [2 CFR 200.38(b)] define a federal award as, ?The instrument setting forth the terms and conditions. The instrument is the grant agreement, cooperative agreement, other agreement for assistance?? Federal regulations [2 CFR 200.510(b)(3) and (4)] require that the SEFA must show both total federal awards expended for each individual federal program, the Assistance Listing Number, and the total amount passed through to subrecipients for each federal program. In order to prepare the SEFA, the OSC requires state departments to submit an Exhibit K1 to report expenditures, receipts, and receivables for each federal grant program administered by the Department during the fiscal year. The OSC?s exhibit instructions include guidelines for completing the Exhibit K1, including defining ?direct and indirect expenditures? as ?all monetary and non-monetary direct and indirect Federal award expenditures,? and ?pass-through expenditures? as ?the amount of all monetary and non-monetary Federal award amounts passed through to a subrecipient.? For the Department?s Grant federal program, subrecipients consist of counties, school districts, and health centers. State Fiscal Rule 1-2, Internal Controls, requires that state departments ?implement internal accounting and administrative controls that reasonably ensure that financial transactions are accurate, reliable, conform to state fiscal rules, and reflect the underlying realities of the accounting transaction (substance rather than form).? Federal regulations [7 CFR 274.4] require the Department to submit an FNS-292-B report in the format prescribed by the USDA with information detailing the P-EBT federal benefit payments. The Department is required to support the information in the report with its underlying records. The FNS-292-B report is identified as a required report within the Department?s State Plan that is approved by the USDA. What problems did the audit work identify? The Department overstated $63.5 million in P-EBT expenditures on its June 2021 FNS-292-B report to USDA that was submitted on August 30, 2021, as well as on the Department?s Exhibit K1 for Fiscal Year 2021. The Department subsequently identified that the FNS-292-B report was misstated and updated and resubmitted the report on September 28, 2021, approximately one month later. The Department, however, did not update its Exhibit K1 for Fiscal Year 2021 to correct the error, because the program staff did not notify the accounting team of the misstatement and need for Exhibit K1 correction. Based on our audit testwork, we also determined that the Department misreported $8.7 million in the Grant?s expenditures as subrecipient, rather than direct, expenditures on its Exhibit K1. Why did these problems occur? The P-EBT program staff did not notify the Department?s accounting team, who prepares the Exhibit K1, of a revision to the FNS-292-B report. The P-EBT program staff prepared the reconciliation of the CBMS summary report to the CFMS P-EBT benefits issued report and identified a variance. The variance was eventually resolved and the P-EBT program staff resubmitted the FNS-292-B report to the USDA; however P-EBT program staff did not communicate this error to the Department?s accounting team. As a result, the accounting team was unaware of the revision and, therefore, did not update the Exhibit K1 to reflect the reduction in federal expenditures. Overall, the Department did not have adequate internal controls, such as an appropriate supervisory review process or adequate communication plan, in place for Fiscal Year 2021 to ensure that the FNS-292-B report was prepared accurately, that the Exhibit K1 was completed in accordance with the instructions provided by the OSC, and that the FNS-292-B and Exhibit K1 were reviewed for accuracy and compared to the underlying data. For the Grant program error, Department staff indicated that these funds were incorrectly identified and coded as subrecipient expenditures in CORE, which caused them to be incorrectly reported as such on the Exhibit K1. When the expenditures were initially posted in CORE, they were not adequately reviewed to determine if they were subrecipient or direct expenditures. Why do these problems matter? By failing to properly report grant expenditures to the federal government and the OSC, who ultimately then fails to properly report expenditures to the federal government on the State?s SEFA, the Department is out of compliance with federal and state reporting requirements and risks federal sanctions. In addition, because the error resulted in the Department misstating its federal expenditure results for the fiscal year, federal staff and taxpayers have an incorrect or unreliable picture of the P-EBT grant?s overall status. See Schedule of Findings and Questioned Costs for chart/table Recommendation 2021-060 The Department of Human Services (Department) should strengthen its internal controls over the preparation of federal reports and the Exhibit K1, Schedule of Federal Assistance, by: A. Strengthening its internal controls over its monthly Pandemic Electronic Benefit Transfer Food Benefits (P-EBT) reporting to ensure its reporting is accurate and goes through supervisory review. B. Improving communication between program and accounting staff to ensure the Exhibit K1 is accurately updated when errors in federal reporting are identified and resolved. C. Improving the supervisory review process over the Exhibit K1 and the federal expenditures entered in the Colorado Operations Resource Engine (CORE), the state?s accounting system, to ensure expenditures are coded correctly as direct or subrecipient expenditures and that, ultimately, the Exhibit K1 is accurate and complete. Response Department of Human Services A. Agree Implementation Date: July 2022 CDHS agrees to enhance internal controls over monthly P-EBT reporting to better ensure accuracy. P-EBT is a new program derived from pandemic funding. Being a new program with a lack of federal guidance at implementation, and urgency to get the funds disbursed program staff had to learn about the nuances of the program and the reporting requirements as it was being implemented. During implementation we recognized that there are some inherent differences with P-EBT from other benefit programs which caused processes to have to be adjusted slightly. Additionally, timing of federal report filing for the P-EBT program is not in synch with our other processes and associated federal reporting requirements and deadlines. This makes it impossible to ensure reconciliation procedures are performed before filing occurs, which is one of our typical internal controls. As a compensating internal control CDHS will ensure that supervisory review processes are performed over P-EBT reporting, and that P-EBT reporting is reconciled to other sources (CBMS and CFMS) as soon as possible after reporting is available. If changes are discovered CDHS will make adjustments to filed P-EBT reports as needed based on reconciliation findings, and communicate changes to necessary parties. B. Agree Implementation Date: July 2022 CDHS will work to ensure better coordination between program activities and the accounting section relating to federal reporting changes. Accounting will iterate the importance of timely informing the accounting staff when changes are made to program filed federal reports. This message will be delivered in periodic fiscal meetings and identified on the closing calendar. The P-EBT program will ensure that corrections are communicated to accounting on any updates completed on the FNS-292-B report upon discovery, and no later than 30 days after the reporting period. C. Agree Implementation Date: July 2022 CDHS will ensure that review and approval processes are occurring as designed at various points in the process leading up to entry into CORE. As part of the Requisition (RQS) approval process program and accounting staff independently approve that the correct direct or subrecipient object code is used. These approved RQS transactions are then transitioned into encumbrance documents that drive which object code future expenditures will be booked to. For CCDF transactions related to this finding, both the OEC and Accounting teams inadvertently approved an incorrect object code in 4 RQS's. Staffing shortages coupled with a large increase in workload related to pandemic funding contributed to this oversight. To correct OEC and Accounting will train new staff, periodically familiarize themselves with the appropriate object codes, and perform quality assurance review over object codes before applying approval in CORE. The K1 is compiled from balances derived from expenditure data recorded in CORE. The compilation of the K1 relies on the fact that expenditure balances are accurate, and that prior reviews and approvals of individual transactions have occurred as designed. The K1 currently goes through various levels of review focusing on balance level validation coupled with analytical procedures. To enhance the review process, CDHS will ensure analytical procedures include line level expenditure comparison at the direct and subrecipient levels.
Finding Number 2022-008 Prior Year Finding Number N/A Compliance Requirement: Allowable Costs/Costs Principles Program: U.S. Department of Education Title I Grants to Local Educational Agencies ALN #: 84.010 Award #: Various Award Period: Various COVID-19 – Governor’s Emergency Education Relief (GEER) ALN #: 84.425C Award #: Various Award Period: Various COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund ALN #: 84.425D Award #: Various Award Period: Various COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR) ALN #: 84.425U Award #: 211941 Award Period: 03/24/2021 – 09/30/2023 COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth ALN #: 84.425W Award #: Various Award Period: Various Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: 1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. 2. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. 3. Records that identify adequately the source and application of funds for federally funded activities. 4. Effective control over, and accountability for, all funds, property, and other assets. The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Further, CFR Section 200.510 (b) requires the auditee must also prepare a Schedule of Expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502, Basis for determining Federal awards expended. Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences: • ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116. In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170. • ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081. Questioned Costs – Not Determinable. Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above. Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements. Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA. Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail. Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks. The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report. BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number 2022-008 Prior Year Finding Number N/A Compliance Requirement: Allowable Costs/Costs Principles Program: U.S. Department of Education Title I Grants to Local Educational Agencies ALN #: 84.010 Award #: Various Award Period: Various COVID-19 – Governor’s Emergency Education Relief (GEER) ALN #: 84.425C Award #: Various Award Period: Various COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund ALN #: 84.425D Award #: Various Award Period: Various COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR) ALN #: 84.425U Award #: 211941 Award Period: 03/24/2021 – 09/30/2023 COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth ALN #: 84.425W Award #: Various Award Period: Various Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: 1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. 2. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. 3. Records that identify adequately the source and application of funds for federally funded activities. 4. Effective control over, and accountability for, all funds, property, and other assets. The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Further, CFR Section 200.510 (b) requires the auditee must also prepare a Schedule of Expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502, Basis for determining Federal awards expended. Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences: • ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116. In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170. • ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081. Questioned Costs – Not Determinable. Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above. Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements. Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA. Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail. Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks. The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report. BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number 2022-008 Prior Year Finding Number N/A Compliance Requirement: Allowable Costs/Costs Principles Program: U.S. Department of Education Title I Grants to Local Educational Agencies ALN #: 84.010 Award #: Various Award Period: Various COVID-19 – Governor’s Emergency Education Relief (GEER) ALN #: 84.425C Award #: Various Award Period: Various COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund ALN #: 84.425D Award #: Various Award Period: Various COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR) ALN #: 84.425U Award #: 211941 Award Period: 03/24/2021 – 09/30/2023 COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth ALN #: 84.425W Award #: Various Award Period: Various Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: 1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. 2. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. 3. Records that identify adequately the source and application of funds for federally funded activities. 4. Effective control over, and accountability for, all funds, property, and other assets. The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Further, CFR Section 200.510 (b) requires the auditee must also prepare a Schedule of Expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502, Basis for determining Federal awards expended. Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences: • ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116. In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170. • ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081. Questioned Costs – Not Determinable. Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above. Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements. Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA. Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail. Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks. The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report. BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number 2022-008 Prior Year Finding Number N/A Compliance Requirement: Allowable Costs/Costs Principles Program: U.S. Department of Education Title I Grants to Local Educational Agencies ALN #: 84.010 Award #: Various Award Period: Various COVID-19 – Governor’s Emergency Education Relief (GEER) ALN #: 84.425C Award #: Various Award Period: Various COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund ALN #: 84.425D Award #: Various Award Period: Various COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR) ALN #: 84.425U Award #: 211941 Award Period: 03/24/2021 – 09/30/2023 COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth ALN #: 84.425W Award #: Various Award Period: Various Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: 1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. 2. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. 3. Records that identify adequately the source and application of funds for federally funded activities. 4. Effective control over, and accountability for, all funds, property, and other assets. The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Further, CFR Section 200.510 (b) requires the auditee must also prepare a Schedule of Expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502, Basis for determining Federal awards expended. Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences: • ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116. In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170. • ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081. Questioned Costs – Not Determinable. Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above. Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements. Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA. Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail. Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks. The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report. BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number 2022-008 Prior Year Finding Number N/A Compliance Requirement: Allowable Costs/Costs Principles Program: U.S. Department of Education Title I Grants to Local Educational Agencies ALN #: 84.010 Award #: Various Award Period: Various COVID-19 – Governor’s Emergency Education Relief (GEER) ALN #: 84.425C Award #: Various Award Period: Various COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund ALN #: 84.425D Award #: Various Award Period: Various COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR) ALN #: 84.425U Award #: 211941 Award Period: 03/24/2021 – 09/30/2023 COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth ALN #: 84.425W Award #: Various Award Period: Various Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: 1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. 2. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. 3. Records that identify adequately the source and application of funds for federally funded activities. 4. Effective control over, and accountability for, all funds, property, and other assets. The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Further, CFR Section 200.510 (b) requires the auditee must also prepare a Schedule of Expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502, Basis for determining Federal awards expended. Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences: • ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116. In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170. • ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081. Questioned Costs – Not Determinable. Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above. Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements. Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA. Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail. Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks. The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report. BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number 2022-008 Prior Year Finding Number N/A Compliance Requirement: Allowable Costs/Costs Principles Program: U.S. Department of Education Title I Grants to Local Educational Agencies ALN #: 84.010 Award #: Various Award Period: Various COVID-19 – Governor’s Emergency Education Relief (GEER) ALN #: 84.425C Award #: Various Award Period: Various COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund ALN #: 84.425D Award #: Various Award Period: Various COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR) ALN #: 84.425U Award #: 211941 Award Period: 03/24/2021 – 09/30/2023 COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth ALN #: 84.425W Award #: Various Award Period: Various Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: 1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. 2. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. 3. Records that identify adequately the source and application of funds for federally funded activities. 4. Effective control over, and accountability for, all funds, property, and other assets. The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Further, CFR Section 200.510 (b) requires the auditee must also prepare a Schedule of Expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502, Basis for determining Federal awards expended. Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences: • ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116. In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170. • ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081. Questioned Costs – Not Determinable. Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above. Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements. Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA. Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail. Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks. The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report. BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number 2022-008 Prior Year Finding Number N/A Compliance Requirement: Allowable Costs/Costs Principles Program: U.S. Department of Education Title I Grants to Local Educational Agencies ALN #: 84.010 Award #: Various Award Period: Various COVID-19 – Governor’s Emergency Education Relief (GEER) ALN #: 84.425C Award #: Various Award Period: Various COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund ALN #: 84.425D Award #: Various Award Period: Various COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR) ALN #: 84.425U Award #: 211941 Award Period: 03/24/2021 – 09/30/2023 COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth ALN #: 84.425W Award #: Various Award Period: Various Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: 1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. 2. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. 3. Records that identify adequately the source and application of funds for federally funded activities. 4. Effective control over, and accountability for, all funds, property, and other assets. The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Further, CFR Section 200.510 (b) requires the auditee must also prepare a Schedule of Expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502, Basis for determining Federal awards expended. Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences: • ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116. In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170. • ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081. Questioned Costs – Not Determinable. Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above. Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements. Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA. Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail. Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks. The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report. BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number 2022-008 Prior Year Finding Number N/A Compliance Requirement: Allowable Costs/Costs Principles Program: U.S. Department of Education Title I Grants to Local Educational Agencies ALN #: 84.010 Award #: Various Award Period: Various COVID-19 – Governor’s Emergency Education Relief (GEER) ALN #: 84.425C Award #: Various Award Period: Various COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund ALN #: 84.425D Award #: Various Award Period: Various COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR) ALN #: 84.425U Award #: 211941 Award Period: 03/24/2021 – 09/30/2023 COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth ALN #: 84.425W Award #: Various Award Period: Various Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: 1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. 2. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. 3. Records that identify adequately the source and application of funds for federally funded activities. 4. Effective control over, and accountability for, all funds, property, and other assets. The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Further, CFR Section 200.510 (b) requires the auditee must also prepare a Schedule of Expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502, Basis for determining Federal awards expended. Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences: • ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116. In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170. • ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081. Questioned Costs – Not Determinable. Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above. Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements. Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA. Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail. Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks. The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report. BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number 2022-008 Prior Year Finding Number N/A Compliance Requirement: Allowable Costs/Costs Principles Program: U.S. Department of Education Title I Grants to Local Educational Agencies ALN #: 84.010 Award #: Various Award Period: Various COVID-19 – Governor’s Emergency Education Relief (GEER) ALN #: 84.425C Award #: Various Award Period: Various COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund ALN #: 84.425D Award #: Various Award Period: Various COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR) ALN #: 84.425U Award #: 211941 Award Period: 03/24/2021 – 09/30/2023 COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth ALN #: 84.425W Award #: Various Award Period: Various Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: 1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. 2. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. 3. Records that identify adequately the source and application of funds for federally funded activities. 4. Effective control over, and accountability for, all funds, property, and other assets. The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Further, CFR Section 200.510 (b) requires the auditee must also prepare a Schedule of Expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502, Basis for determining Federal awards expended. Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences: • ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116. In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170. • ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081. Questioned Costs – Not Determinable. Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above. Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements. Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA. Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail. Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks. The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report. BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number 2022-008 Prior Year Finding Number N/A Compliance Requirement: Allowable Costs/Costs Principles Program: U.S. Department of Education Title I Grants to Local Educational Agencies ALN #: 84.010 Award #: Various Award Period: Various COVID-19 – Governor’s Emergency Education Relief (GEER) ALN #: 84.425C Award #: Various Award Period: Various COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund ALN #: 84.425D Award #: Various Award Period: Various COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR) ALN #: 84.425U Award #: 211941 Award Period: 03/24/2021 – 09/30/2023 COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth ALN #: 84.425W Award #: Various Award Period: Various Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: 1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. 2. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. 3. Records that identify adequately the source and application of funds for federally funded activities. 4. Effective control over, and accountability for, all funds, property, and other assets. The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Further, CFR Section 200.510 (b) requires the auditee must also prepare a Schedule of Expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502, Basis for determining Federal awards expended. Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences: • ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116. In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170. • ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081. Questioned Costs – Not Determinable. Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above. Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements. Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA. Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail. Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks. The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report. BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number 2022-008 Prior Year Finding Number N/A Compliance Requirement: Allowable Costs/Costs Principles Program: U.S. Department of Education Title I Grants to Local Educational Agencies ALN #: 84.010 Award #: Various Award Period: Various COVID-19 – Governor’s Emergency Education Relief (GEER) ALN #: 84.425C Award #: Various Award Period: Various COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund ALN #: 84.425D Award #: Various Award Period: Various COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR) ALN #: 84.425U Award #: 211941 Award Period: 03/24/2021 – 09/30/2023 COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth ALN #: 84.425W Award #: Various Award Period: Various Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: 1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. 2. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. 3. Records that identify adequately the source and application of funds for federally funded activities. 4. Effective control over, and accountability for, all funds, property, and other assets. The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Further, CFR Section 200.510 (b) requires the auditee must also prepare a Schedule of Expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502, Basis for determining Federal awards expended. Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences: • ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116. In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170. • ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081. Questioned Costs – Not Determinable. Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above. Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements. Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA. Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail. Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks. The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report. BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number 2022-008 Prior Year Finding Number N/A Compliance Requirement: Allowable Costs/Costs Principles Program: U.S. Department of Education Title I Grants to Local Educational Agencies ALN #: 84.010 Award #: Various Award Period: Various COVID-19 – Governor’s Emergency Education Relief (GEER) ALN #: 84.425C Award #: Various Award Period: Various COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund ALN #: 84.425D Award #: Various Award Period: Various COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR) ALN #: 84.425U Award #: 211941 Award Period: 03/24/2021 – 09/30/2023 COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth ALN #: 84.425W Award #: Various Award Period: Various Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: 1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. 2. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. 3. Records that identify adequately the source and application of funds for federally funded activities. 4. Effective control over, and accountability for, all funds, property, and other assets. The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Further, CFR Section 200.510 (b) requires the auditee must also prepare a Schedule of Expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502, Basis for determining Federal awards expended. Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences: • ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116. In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170. • ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081. Questioned Costs – Not Determinable. Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above. Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements. Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA. Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail. Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks. The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report. BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number 2022-008 Prior Year Finding Number N/A Compliance Requirement: Allowable Costs/Costs Principles Program: U.S. Department of Education Title I Grants to Local Educational Agencies ALN #: 84.010 Award #: Various Award Period: Various COVID-19 – Governor’s Emergency Education Relief (GEER) ALN #: 84.425C Award #: Various Award Period: Various COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund ALN #: 84.425D Award #: Various Award Period: Various COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR) ALN #: 84.425U Award #: 211941 Award Period: 03/24/2021 – 09/30/2023 COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth ALN #: 84.425W Award #: Various Award Period: Various Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: 1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. 2. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. 3. Records that identify adequately the source and application of funds for federally funded activities. 4. Effective control over, and accountability for, all funds, property, and other assets. The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Further, CFR Section 200.510 (b) requires the auditee must also prepare a Schedule of Expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502, Basis for determining Federal awards expended. Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences: • ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116. In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170. • ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081. Questioned Costs – Not Determinable. Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above. Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements. Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA. Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail. Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks. The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report. BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number 2022-008 Prior Year Finding Number N/A Compliance Requirement: Allowable Costs/Costs Principles Program: U.S. Department of Education Title I Grants to Local Educational Agencies ALN #: 84.010 Award #: Various Award Period: Various COVID-19 – Governor’s Emergency Education Relief (GEER) ALN #: 84.425C Award #: Various Award Period: Various COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund ALN #: 84.425D Award #: Various Award Period: Various COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR) ALN #: 84.425U Award #: 211941 Award Period: 03/24/2021 – 09/30/2023 COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth ALN #: 84.425W Award #: Various Award Period: Various Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: 1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. 2. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. 3. Records that identify adequately the source and application of funds for federally funded activities. 4. Effective control over, and accountability for, all funds, property, and other assets. The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Further, CFR Section 200.510 (b) requires the auditee must also prepare a Schedule of Expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502, Basis for determining Federal awards expended. Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences: • ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116. In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170. • ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081. Questioned Costs – Not Determinable. Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above. Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements. Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA. Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail. Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks. The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report. BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number 2022-008 Prior Year Finding Number N/A Compliance Requirement: Allowable Costs/Costs Principles Program: U.S. Department of Education Title I Grants to Local Educational Agencies ALN #: 84.010 Award #: Various Award Period: Various COVID-19 – Governor’s Emergency Education Relief (GEER) ALN #: 84.425C Award #: Various Award Period: Various COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund ALN #: 84.425D Award #: Various Award Period: Various COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR) ALN #: 84.425U Award #: 211941 Award Period: 03/24/2021 – 09/30/2023 COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth ALN #: 84.425W Award #: Various Award Period: Various Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: 1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. 2. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. 3. Records that identify adequately the source and application of funds for federally funded activities. 4. Effective control over, and accountability for, all funds, property, and other assets. The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Further, CFR Section 200.510 (b) requires the auditee must also prepare a Schedule of Expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502, Basis for determining Federal awards expended. Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences: • ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116. In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170. • ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081. Questioned Costs – Not Determinable. Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above. Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements. Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA. Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail. Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks. The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report. BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number 2022-008 Prior Year Finding Number N/A Compliance Requirement: Allowable Costs/Costs Principles Program: U.S. Department of Education Title I Grants to Local Educational Agencies ALN #: 84.010 Award #: Various Award Period: Various COVID-19 – Governor’s Emergency Education Relief (GEER) ALN #: 84.425C Award #: Various Award Period: Various COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund ALN #: 84.425D Award #: Various Award Period: Various COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR) ALN #: 84.425U Award #: 211941 Award Period: 03/24/2021 – 09/30/2023 COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth ALN #: 84.425W Award #: Various Award Period: Various Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: 1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. 2. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. 3. Records that identify adequately the source and application of funds for federally funded activities. 4. Effective control over, and accountability for, all funds, property, and other assets. The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Further, CFR Section 200.510 (b) requires the auditee must also prepare a Schedule of Expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502, Basis for determining Federal awards expended. Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences: • ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116. In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170. • ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081. Questioned Costs – Not Determinable. Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above. Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements. Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA. Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail. Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks. The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report. BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number 2022-008 Prior Year Finding Number N/A Compliance Requirement: Allowable Costs/Costs Principles Program: U.S. Department of Education Title I Grants to Local Educational Agencies ALN #: 84.010 Award #: Various Award Period: Various COVID-19 – Governor’s Emergency Education Relief (GEER) ALN #: 84.425C Award #: Various Award Period: Various COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund ALN #: 84.425D Award #: Various Award Period: Various COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR) ALN #: 84.425U Award #: 211941 Award Period: 03/24/2021 – 09/30/2023 COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth ALN #: 84.425W Award #: Various Award Period: Various Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: 1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. 2. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. 3. Records that identify adequately the source and application of funds for federally funded activities. 4. Effective control over, and accountability for, all funds, property, and other assets. The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Further, CFR Section 200.510 (b) requires the auditee must also prepare a Schedule of Expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502, Basis for determining Federal awards expended. Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences: • ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116. In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170. • ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081. Questioned Costs – Not Determinable. Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above. Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements. Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA. Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail. Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks. The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report. BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Assistance Listing, Federal Agency, and Program Name - Assistance Listing 66.443, Environmental Protection Agency, Reducing Lead in Drinking Water Federal Award Identification Number and Year - OOE02968, 2021 Pass-through Entity - n/a Finding Type - Material weakness Repeat Finding - No Criteria - 2 CFR 200.508 requires the City to prepare appropriate financial statements, including the schedule of expenditures of federal awards (SEFA) in accordance with 2 CFR 200.510. The SEFA must list individual federal programs as required by 2 CFR 200.501(b)(1). The SEFA is the basis for the auditor determination of major programs as required by 2 CFR 200.518. Condition - The original SEFA prepared for audit purposes did not include all federal expenditures that should have been reported under ALN 66.443. Questioned Costs - None Identification of How Questioned Costs Were Computed - n/a Context - Approximately $864,000 of federal expenditures were not included in the original SEFA prepared for audit purposes under ALN 66.443. Cause and Effect - The City's controls over reconciling the SEFA to federal revenue did not detect the missing expenditures because federal revenue was not appropriately accrued by $864,000. As a result, ALN 66.443 was not originally identified as a major program. Recommendation - The City should review its controls over preparation of the SEFA and reconciling the SEFA to federal expenditures per the general ledger to ensure the appropriate amount of federal expenditures are reported on the SEFA. Views of Responsible Officials and Corrective Action Plan - We agree with the auditor’s recommendation. Changes have been implemented to ensure all programs with both federal and state/local funding will be examined to ensure correct expenditure by funding source is properly recorded.
Finding 2022-002 – Internal Control Deficiency and Noncompliance over Reporting Identification of the Federal Program: Federal Grantor: United States Department of the Treasury Pass-Through Entity: Smith County, Texas and the City of San Marcos, Texas Assistance Listing No.:21.027, Coronavirus State and Local Fiscal Recovery Funds Pass-Through Award Numbers: Not available Award Periods of Performance: Trinity Mother Frances, Pass-through Smith County, October 1, 2021 – November 30, 2021 Santa Rosa, Pass-through the City of San Marcos, March 03, 2021 through December 31, 2026 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): The Uniform Guidance 2 CFR section 200.303 states, “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.” Condition: CHRISTUS did not originally prepare a complete and accurate listing of all federal awards in the SEFA. Cause: CHRISTUS did not have controls in place to ensure all federal expenditures were captured on the SEFA. Effect or Potential Effect: The SEFA prepared by CHRISTUS was misstated but was subsequently corrected. The misstatement resulted in the omission of a major federal program under the Uniform Guidance report. Questioned Costs: None. Context: Expenditures for Assistance Listing Number 21.027 were originally understated on the SEFA by $2,500,000, or 71% of the program. Identification as a Repeat Finding, if Applicable: This is not a repeat finding. Recommendation: CHRISTUS should review its internal controls over the process of accumulating and reporting expenditures of federal awards. Views of Responsible Officials: CHRISTUS agrees with the finding and has developed internal controls to ensure accurate and complete reporting of federal expenditures.
Finding 2022-002 – Internal Control Deficiency and Noncompliance over Reporting Identification of the Federal Program: Federal Grantor: United States Department of the Treasury Pass-Through Entity: Smith County, Texas and the City of San Marcos, Texas Assistance Listing No.:21.027, Coronavirus State and Local Fiscal Recovery Funds Pass-Through Award Numbers: Not available Award Periods of Performance: Trinity Mother Frances, Pass-through Smith County, October 1, 2021 – November 30, 2021 Santa Rosa, Pass-through the City of San Marcos, March 03, 2021 through December 31, 2026 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): The Uniform Guidance 2 CFR section 200.303 states, “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.” Condition: CHRISTUS did not originally prepare a complete and accurate listing of all federal awards in the SEFA. Cause: CHRISTUS did not have controls in place to ensure all federal expenditures were captured on the SEFA. Effect or Potential Effect: The SEFA prepared by CHRISTUS was misstated but was subsequently corrected. The misstatement resulted in the omission of a major federal program under the Uniform Guidance report. Questioned Costs: None. Context: Expenditures for Assistance Listing Number 21.027 were originally understated on the SEFA by $2,500,000, or 71% of the program. Identification as a Repeat Finding, if Applicable: This is not a repeat finding. Recommendation: CHRISTUS should review its internal controls over the process of accumulating and reporting expenditures of federal awards. Views of Responsible Officials: CHRISTUS agrees with the finding and has developed internal controls to ensure accurate and complete reporting of federal expenditures.
Finding 2022-002 – Internal Control Deficiency and Noncompliance over Reporting Identification of the Federal Program: Federal Grantor: United States Department of the Treasury Pass-Through Entity: Smith County, Texas and the City of San Marcos, Texas Assistance Listing No.:21.027, Coronavirus State and Local Fiscal Recovery Funds Pass-Through Award Numbers: Not available Award Periods of Performance: Trinity Mother Frances, Pass-through Smith County, October 1, 2021 – November 30, 2021 Santa Rosa, Pass-through the City of San Marcos, March 03, 2021 through December 31, 2026 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): The Uniform Guidance 2 CFR section 200.303 states, “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.” Condition: CHRISTUS did not originally prepare a complete and accurate listing of all federal awards in the SEFA. Cause: CHRISTUS did not have controls in place to ensure all federal expenditures were captured on the SEFA. Effect or Potential Effect: The SEFA prepared by CHRISTUS was misstated but was subsequently corrected. The misstatement resulted in the omission of a major federal program under the Uniform Guidance report. Questioned Costs: None. Context: Expenditures for Assistance Listing Number 21.027 were originally understated on the SEFA by $2,500,000, or 71% of the program. Identification as a Repeat Finding, if Applicable: This is not a repeat finding. Recommendation: CHRISTUS should review its internal controls over the process of accumulating and reporting expenditures of federal awards. Views of Responsible Officials: CHRISTUS agrees with the finding and has developed internal controls to ensure accurate and complete reporting of federal expenditures.