Finding 2024-002: Preparation of the Schedule of Expenditures of Federal Awards (SEFA) Federal Agency: U.S. Department of Commerce. Federal Programs: Ocean Exploration, Coastal Zone Management Administration Awards, Marine Sanctuary Program, Unallied Management Projects, Habitat Conservation, Building Resilience through Community Stewardship of Coral Reefs, Marine Debris Program. Assistance Listing Numbers: 11.011, 11.419, 11.429, 11.454, 11.463, 11.473, 11.999. Compliance Requirement: Reporting. Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance. Criteria: Per 2 CFR §200.510(b), the auditee must prepare a SEFA that includes total Federal expenditures, the name of the Federal agency, the Assistance Listing Number, and other identifying information. The SEFA must be accurate, complete, and prepared in accordance with the Uniform Guidance to facilitate the Single Audit. Condition: During our audit of the SEFA for the year ended December 31, 2024, we noted that the initial SEFA provided by management contained material inaccuracies. Specifically, we noted that amounts passed through to subrecipients were not properly reported and certain programs had expenditures that were inaccurately reported. Cause: The inaccuracies in the SEFA were primarily due to a lack of formalized procedures and oversight in the SEFA preparation process. Effect or Potential Effect: An incomplete or inaccurate SEFA may result in inadequate audit coverage, potential noncompliance with Federal reporting requirements, and increased risk of questioned costs or funding disallowances. Questioned Costs: None. Context: The initial SEFA provided for audit included approximately $310,000 passed through to subrecipients. During the performance of our audit procedures, we identified approximately $5.2 million in amounts passed through to subrecipients that were omitted. Additionally, other expenses were omitted from the SEFA as well. The SEFA was subsequently revised and corrected by management. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management implement formal procedures for compiling the SEFA, including a reconciliation of expenditures to the general ledger, review of all grant agreements for required disclosures, and a documented supervisory review prior to finalization. Staff involved in Federal grant reporting should also receive training on SEFA requirements under Uniform Guidance.
Finding 2024-002: Preparation of the Schedule of Expenditures of Federal Awards (SEFA) Federal Agency: U.S. Department of Commerce. Federal Programs: Ocean Exploration, Coastal Zone Management Administration Awards, Marine Sanctuary Program, Unallied Management Projects, Habitat Conservation, Building Resilience through Community Stewardship of Coral Reefs, Marine Debris Program. Assistance Listing Numbers: 11.011, 11.419, 11.429, 11.454, 11.463, 11.473, 11.999. Compliance Requirement: Reporting. Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance. Criteria: Per 2 CFR §200.510(b), the auditee must prepare a SEFA that includes total Federal expenditures, the name of the Federal agency, the Assistance Listing Number, and other identifying information. The SEFA must be accurate, complete, and prepared in accordance with the Uniform Guidance to facilitate the Single Audit. Condition: During our audit of the SEFA for the year ended December 31, 2024, we noted that the initial SEFA provided by management contained material inaccuracies. Specifically, we noted that amounts passed through to subrecipients were not properly reported and certain programs had expenditures that were inaccurately reported. Cause: The inaccuracies in the SEFA were primarily due to a lack of formalized procedures and oversight in the SEFA preparation process. Effect or Potential Effect: An incomplete or inaccurate SEFA may result in inadequate audit coverage, potential noncompliance with Federal reporting requirements, and increased risk of questioned costs or funding disallowances. Questioned Costs: None. Context: The initial SEFA provided for audit included approximately $310,000 passed through to subrecipients. During the performance of our audit procedures, we identified approximately $5.2 million in amounts passed through to subrecipients that were omitted. Additionally, other expenses were omitted from the SEFA as well. The SEFA was subsequently revised and corrected by management. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management implement formal procedures for compiling the SEFA, including a reconciliation of expenditures to the general ledger, review of all grant agreements for required disclosures, and a documented supervisory review prior to finalization. Staff involved in Federal grant reporting should also receive training on SEFA requirements under Uniform Guidance.
Finding 2024-002: Preparation of the Schedule of Expenditures of Federal Awards (SEFA) Federal Agency: U.S. Department of Commerce. Federal Programs: Ocean Exploration, Coastal Zone Management Administration Awards, Marine Sanctuary Program, Unallied Management Projects, Habitat Conservation, Building Resilience through Community Stewardship of Coral Reefs, Marine Debris Program. Assistance Listing Numbers: 11.011, 11.419, 11.429, 11.454, 11.463, 11.473, 11.999. Compliance Requirement: Reporting. Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance. Criteria: Per 2 CFR §200.510(b), the auditee must prepare a SEFA that includes total Federal expenditures, the name of the Federal agency, the Assistance Listing Number, and other identifying information. The SEFA must be accurate, complete, and prepared in accordance with the Uniform Guidance to facilitate the Single Audit. Condition: During our audit of the SEFA for the year ended December 31, 2024, we noted that the initial SEFA provided by management contained material inaccuracies. Specifically, we noted that amounts passed through to subrecipients were not properly reported and certain programs had expenditures that were inaccurately reported. Cause: The inaccuracies in the SEFA were primarily due to a lack of formalized procedures and oversight in the SEFA preparation process. Effect or Potential Effect: An incomplete or inaccurate SEFA may result in inadequate audit coverage, potential noncompliance with Federal reporting requirements, and increased risk of questioned costs or funding disallowances. Questioned Costs: None. Context: The initial SEFA provided for audit included approximately $310,000 passed through to subrecipients. During the performance of our audit procedures, we identified approximately $5.2 million in amounts passed through to subrecipients that were omitted. Additionally, other expenses were omitted from the SEFA as well. The SEFA was subsequently revised and corrected by management. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management implement formal procedures for compiling the SEFA, including a reconciliation of expenditures to the general ledger, review of all grant agreements for required disclosures, and a documented supervisory review prior to finalization. Staff involved in Federal grant reporting should also receive training on SEFA requirements under Uniform Guidance.
Finding 2024-002: Preparation of the Schedule of Expenditures of Federal Awards (SEFA) Federal Agency: U.S. Department of Commerce. Federal Programs: Ocean Exploration, Coastal Zone Management Administration Awards, Marine Sanctuary Program, Unallied Management Projects, Habitat Conservation, Building Resilience through Community Stewardship of Coral Reefs, Marine Debris Program. Assistance Listing Numbers: 11.011, 11.419, 11.429, 11.454, 11.463, 11.473, 11.999. Compliance Requirement: Reporting. Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance. Criteria: Per 2 CFR §200.510(b), the auditee must prepare a SEFA that includes total Federal expenditures, the name of the Federal agency, the Assistance Listing Number, and other identifying information. The SEFA must be accurate, complete, and prepared in accordance with the Uniform Guidance to facilitate the Single Audit. Condition: During our audit of the SEFA for the year ended December 31, 2024, we noted that the initial SEFA provided by management contained material inaccuracies. Specifically, we noted that amounts passed through to subrecipients were not properly reported and certain programs had expenditures that were inaccurately reported. Cause: The inaccuracies in the SEFA were primarily due to a lack of formalized procedures and oversight in the SEFA preparation process. Effect or Potential Effect: An incomplete or inaccurate SEFA may result in inadequate audit coverage, potential noncompliance with Federal reporting requirements, and increased risk of questioned costs or funding disallowances. Questioned Costs: None. Context: The initial SEFA provided for audit included approximately $310,000 passed through to subrecipients. During the performance of our audit procedures, we identified approximately $5.2 million in amounts passed through to subrecipients that were omitted. Additionally, other expenses were omitted from the SEFA as well. The SEFA was subsequently revised and corrected by management. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management implement formal procedures for compiling the SEFA, including a reconciliation of expenditures to the general ledger, review of all grant agreements for required disclosures, and a documented supervisory review prior to finalization. Staff involved in Federal grant reporting should also receive training on SEFA requirements under Uniform Guidance.
Finding 2024-002: Preparation of the Schedule of Expenditures of Federal Awards (SEFA) Federal Agency: U.S. Department of Commerce. Federal Programs: Ocean Exploration, Coastal Zone Management Administration Awards, Marine Sanctuary Program, Unallied Management Projects, Habitat Conservation, Building Resilience through Community Stewardship of Coral Reefs, Marine Debris Program. Assistance Listing Numbers: 11.011, 11.419, 11.429, 11.454, 11.463, 11.473, 11.999. Compliance Requirement: Reporting. Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance. Criteria: Per 2 CFR §200.510(b), the auditee must prepare a SEFA that includes total Federal expenditures, the name of the Federal agency, the Assistance Listing Number, and other identifying information. The SEFA must be accurate, complete, and prepared in accordance with the Uniform Guidance to facilitate the Single Audit. Condition: During our audit of the SEFA for the year ended December 31, 2024, we noted that the initial SEFA provided by management contained material inaccuracies. Specifically, we noted that amounts passed through to subrecipients were not properly reported and certain programs had expenditures that were inaccurately reported. Cause: The inaccuracies in the SEFA were primarily due to a lack of formalized procedures and oversight in the SEFA preparation process. Effect or Potential Effect: An incomplete or inaccurate SEFA may result in inadequate audit coverage, potential noncompliance with Federal reporting requirements, and increased risk of questioned costs or funding disallowances. Questioned Costs: None. Context: The initial SEFA provided for audit included approximately $310,000 passed through to subrecipients. During the performance of our audit procedures, we identified approximately $5.2 million in amounts passed through to subrecipients that were omitted. Additionally, other expenses were omitted from the SEFA as well. The SEFA was subsequently revised and corrected by management. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management implement formal procedures for compiling the SEFA, including a reconciliation of expenditures to the general ledger, review of all grant agreements for required disclosures, and a documented supervisory review prior to finalization. Staff involved in Federal grant reporting should also receive training on SEFA requirements under Uniform Guidance.
Assistance Number: 16.753 Congressionally Recommended Awards (CRA) Year: 2024 Name of Federal Agency: U.S. Department of Justice Name of Pass-Thru Agency: Direct award Type of Compliance Finding: B – Allowable Costs/Cost Principles Condition: 2 CFR Part 200, section 200.510 requires the City to prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the financial statements. The City’s Schedule of Expenditures of Federal Awards (SEFA) for the year ended December 31, 2024, included expenditures that were incurred in the prior fiscal year. These prior year expenditures were not reported on the 2023 SEFA and incorrectly reported in the current year Criteria: An entity that expends federal awards must have controls in place that would enable the entity to prepare a SEFA including controls that determine the accuracy of the amount of expenditures reported for each federal program. In accordance with 2 CFR §200.502(a), expenditures are to be reported on the SEFA in the fiscal year in which the activity related to the federal award occurs. Questioned Costs: N/A Context: The City did not report $705,791 of expenses on the 2023 SEFA and instead reported these amounts on the 2024 SEFA. Cause: The error occurred due to inadequate review procedures over the preparation of the SEFA. Specifically, the City did not reconcile SEFA amounts to program reports to ensure expenditures were reported correctly at year-end. Effect: The SEFA understated expenditures in the prior year and overstated expenditures in the current year, potentially misleading federal agencies and pass-through entities about the City’s use of federal funds. This could impact risk assessments, reporting accuracy, and decisions regarding future funding. The lack of an accurate and complete SEFA could lead to grant noncompliance and noncompliance with Subpart F, Audit Requirements, of 2 CFR Part 200. Recommendation: We recommend the City strengthen its SEFA preparation and review process by: • Reconciling federal expenditures reported on the SEFA to the general ledger by program and grant year. • Implementing a secondary review to verify that no prior year expenditures are included in current year reporting. • Providing staff with training on SEFA preparation requirements under 2 CFR Part 200. Views of Responsible Officials (Unaudited): City leadership agrees with the auditor’s finding and appreciates the recommendations for improvements. The same root causes identified in Finding 2024-003 – system transition, staff turnover, and decentralized grant management – contributed to this compliance issue. The City recognizes the need for stronger internal controls, centralized oversight, and consistent review of grant management.
#2024-007 – Major Federal Award Finding – Federal Grants Management Nature of Finding: Federal Grants Management – Preparation and Maintenance of Schedule of Expenditures of Federal Awards Compliance Finding and Significant Deficiency in Internal Controls over Compliance Criteria/Condition: Per 2 CFR 200.510(b), the auditee must prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total federal awards expended, as determined in accordance with §200.502. For SEFA reporting, the components of the SEFA were not accurately maintained. Cause/Context: While the Organization has a policy related to grant administration and tracking of expenditures, the procedures and controls relating to the policy were not properly implemented during 2024. Effect: Expenditures for the Coronavirus State and Local Fiscal Recovery Funds grants were not accurately reported on the auditee-prepared SEFA. The SEFA presented has been adjusted for these errors. Controls in place did not sufficiently ensure the completeness and accuracy of the SEFA. Recommendation: We recommend the Organization enhance its procedures and controls to ensure data accumulated to prepare the SEFA is complete and accurate. Views of Responsible Officials and Planned Corrective Actions: We lacked consistent grant-level financial reporting, which made preparation of the required Schedule of Expenditures of Federal Awards (SEFA) difficult and time consuming. We have improved our accounting systems and can now procedure regular internal financial reports by grant. All grant managers are given a monthly transaction listing for their grants to ensure transactions are posted to the correct grant. They are also given monthly financial statements for each grant to reconcile to their records. Financial reporting will be done on a timely basis, ideally no more than 5 days after the month closing so grant managers can reconcile their records.
Finding 2024-001 – ReportingInformation of the federal program:Federal Grantor: Department of Health and Human Services (HHS)Assistance Listing No.: 93.391, COVID-19 Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare CrisisPass-Through Grantor: Chicago Department of Public HealthFederal Grantor: Department of Health and Human Services (HHS)Assistance Listing No.: 93.323, COVID-19 Epidemiology and Laboratory Capacity for Infectious DiseasesPass-Through Grantor: Chicago Department of Public HealthCriteria or specific requirement (including statutory, regulatory, or other citation):Section 200.303 of the Uniform Guidance states the following regarding internal control: “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:Certain expenditures related to the COVID-19 Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crisis and the COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases were overstated by $347,352 and $164,120, respectively, on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.Cause:Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.Effect or Potential Effect:Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.Questioned costs:None.Context:Endeavor reported expenditures of $872,758 on the preliminary SEFA, but on the final SEFA reported $525,406 related to the COVID-19 Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crisis. Endeavor reported expenditures of $1,233,464 on the preliminary SEFA, but on the final SEFA reported $1,069,344 related to the COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases.Identification as a repeat finding, if applicable:This is a repeat finding of 2023-001.Recommendation:Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.Views of responsible officials:Management acknowledges the findings related to SEFA reporting. The issue arose from miscommunication in determining which expenditures should be reported for the programs in question. We recognize the importance of accurate and complete reporting. We will enhance our review and communication processes to ensure clarity between program managers and the finance team when identifying reportable expenditures. We have already taken steps to address this issue by:• Creating a new policy and procedure for SEFA reporting and establishing clear guidance and documentation for expenses that should be included in the SEFA.• Implementing an expanded review process to ensure accuracy prior to submission.
Program name: State and Local Fiscal Recover Funds Assistance Listing: 21.027, 14.239, 14,231 Federal award Identification number: All Federal award year: All Federal awarding agency: U.S. Department of Treasury and U.S. Department of Housing and Urban Development Criteria: In accordance with 2 CFR 200.510(b), the auditee must prepare a complete and accurate Schedule of Expenditures of Federal Awards (SEFA) that include the total federal awards expended for each federal program, the assistance listing number (ALN), the name of the federal agency, and the pass-through entity identifying number. Accurate SEFA reporting is essential to support the auditor's responsibility under 2 CFR 200.518 major program determination and for federal oversight. Condition: The Organization failed to include the correct amount of expenditures and the ALN numbers. The awards were identified as federal during the current audit; however, the Organization failed to include the ALN in the current year’s SEFA. After additional inquiry and evaluation, they were determined to fall under ALN 14.239, 14.231 and 21.027. Cause: There were deficiencies in the Organizations's internal controls over the SEFA preparation, specifically identifying the current ALN number for each federal award. The absence of the assistance listing number indicates inadequate review and verification procedures. Effect or Potential Effect: Incomplete and inaccurate SEFA reporting may lead to noncompliance with Uniform Guidance requirements and increases the risk of omitted or misclassified programs subject to audit. Missing ALNs may also hinder proper audit coverage and oversight by federal and pass-through entities. Repeat finding: This is not a repeat finding. Perspective: This issue affected three federal awards and represents a systemic control issue over SEFA preparation. There is a reasonable possibility that similar issues could recur if not addressed. Questioned costs: There are no questioned costs associated with this finding. Perspective: This issue affected two federal awards and represents a systemic control issue over SEFA preparation. There is a reasonable possibility that similar issues could recur if not addressed. Recommendation: We recommend that the Organization: Enhance internal controls over the SEFA preparation process to ensure federal programs are accurately identified, classified, and reported, including verification of ALNs. Designate responsibility within the finance team for verifying the federal nature of all awards and ensure ongoing training on SEFA and Uniform Guidance Requirements. Management’s response and corrective action plan (unaudited): See corrective action plan
Criteria: In accordance with 2 CFR § 200.510(b), recipients of federal awards are required to prepare a complete and accurate Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements. The SEFA must include all federal awards expended during the fiscal year and must be prepared in accordance with the requirements of the Uniform Guidance. Condition: During our audit of the SEFA, we noted that approximately $1.2 million in federal expenditures were initially omitted from the draft schedule provided by management. These expenditures were related to pass-through awards and were not identified or reported until audit inquiries were made. Cause: The entity did not have adequate internal control procedures in place to ensure that all federal expenditures were identified and included in the SEFA prior to audit. Effect: The initial SEFA provided for audit was materially misstated. Failure to accurately report all federal expenditures on the SEFA could result in noncompliance with Uniform Guidance reporting requirements, misrepresentation of the scope of federal activity, and potential exclusion of federal programs from audit coverage under the Single Audit Act. This increases the risk that material noncompliance in major programs may go undetected.Questioned Costs: None. Recommendation: We recommend that management implement stronger internal controls over the preparation of the SEFA, including reconciliation procedures between the general ledger and grant records, periodic reviews during the year, and oversight by personnel with a thorough understanding of federal reporting requirements. Management should ensure that all departments responsible for federal programs provide complete and timely information to accounting personnel for SEFA preparation. Organization Response: Management agrees with this finding.
Federal Program(s): Enhanced Mobility of Seniors and Individuals with Disabilities (ALN 20.513) Agencies: U.S. Department of Transportation – Federal Transit Administration Criteria - 2 CFR §200.510: Auditee must prepare an accurate SEFA including ALN, program name, award number, award year, pass-through number, and total expenditures. 2 CFR §200.332: Pass-through entities must identify the ALN in all subaward documents. 2 CFR §200.303: Auditees must establish and maintain effective internal controls over federal awards. Condition - During our audit of ENVIDA’s federal programs, we identified an internal control deficiency affecting the accuracy of the Schedule of Expenditures of Federal Awards (SEFA). Context - The issue stems from the Envida's need to formalize documented procedures and adequate review over the SEFA preparation process, as well as the need to implement controls for verifying federal award information received from pass-through entities. Specifically, ENVIDA’s SEFA included initial misstatements, including erroneous reporting of $61,576 in required matched funds as federal expenditures (which they were not), the inclusion of $79,225 in OnDemand expenditures that were not federally funded (incorrect information from passthrough entity), and a $45,403 posting error that misclassified expenditures between grant years. These errors resulted in a material overstatement of the SEFA federal expenditures as originally prepared. Management corrected these errors during the audit process. Cause - Due to lack of funding information provided in the contracts with a major passthrough entity, Envida is unable to verify accuracy of federal funding information contemporaneously. For 2024, incomplete or inaccurate information from pass-through entities, coupled with the absence of formalized internal controls to verify and document federal award details, led to initial errors in SEFA reporting. Contracts with the pass-through entity, Pikes Peak Area Council of Governments (PPACG), did not include the required Assistance Listing Numbers (ALNs), which contributed to the confusion and misreporting. These deficiencies are inconsistent with the requirements of 2 CFR §200.510(b), §200.303, and §200.332(a)(1), which collectively mandate accurate SEFA reporting, proper identification of federal awards, and internal controls over federal funding. Effect - SEFA initially overstated by 15.5% due to match and OnDemand errors. FY24 award overstated by 17.5%; FY25 award understated by 14.6% Potential audit coverage gaps and risk misassessment under 2 CFR §200.518. Recommendation - We recommend that ENVIDA establish and document clear procedures for the preparation of the Schedule of Expenditures of Federal Awards (SEFA) as well as for the proper classification of accounts receivable. In addition, ENVIDA should implement a supervisory review process to help ensure accuracy and compliance with federal requirements. To further strengthen controls, all subaward agreements should require written confirmation of the Assistance Listing Numbers (ALNs). Finally, ENVIDA should verify federal award information directly against official federal award notices prior to preparing the SEFA. Views of Responsible Official and Planned Corrective Action - Management has agreed with the finding and plans to revise the SEFA to reflect accurate federal expenditures. They will work with pass-through entities to ensure future subaward documentation includes all required federal award identifiers and will implement internal controls to prevent recurrence.
2024-003: Significant Deficiency: Reporting Criteria: The Code of Federal Regulations (CFR) section 200.510 (b) states that the audit, the data collection form, and the reporting package must be submitted within 30 calendar days after the auditee receives the auditor's report(s) or nine months after the end of the audit period (whichever is earlier) to the Federal Audit Clearinghouse (FAC). Condition: During the audit the Organization submitted the December 31, 2023 required reporting package to the FAC 167 days past the deadline without an approved extension from the oversight agency. Cause: The Organization had not implemented policies or procedures, to the degree necessary, to ensure that the audit, data collection form, and reporting package was complete, accurate, and submitted within the required time frame. Effect: The Organization was not in compliance with federal regulations. Section III: Federal Award Findings and Questioned Costs (Continued) 2024-003: Significant Deficiency: Reporting (Continued) Recommendation: We recommend that management of the Organization implement policies, procedures, and internal controls over compliance to ensure that required federal reporting is timely and in accordance with federal regulations. Views of Responsible Officials: Management agrees with this finding and their response is included in the corrective action plan.
2024-005- Internal Control over Grant Monitoring and Reporting Finding Type: Material Weakness in Internal Control and Material Noncompliance in accordance with Uniform Guidance. Federal Program and Agency: Airport Improvement Program – ALN #20.106; U.S. Department of Transportation – Federal Aviation Administration (FAA) Repeat Finding: No Criteria: Per 2 CFR § 200.303 and 2 CFR § 200.510(b), the recipient is required to establish and maintain effective internal control over federal awards and to ensure complete and accurate reporting of all federal expenditures on the Schedule of Expenditures of Federal Awards (SEFA). Adequate oversight and reconciliation processes must be in place to ensure all allowable expenditures are properly recorded and submitted for reimbursement. Condition: During the financial audit for fiscal year ending December 31, 2024, it was identified that approximately $2.7 million in expenditures related to a federally funded airport construction project were not communicated to the finance department in a timely manner. Consequently, the expenses were not reported in the correct accounting period and were excluded from the County’s grant monitoring process. These expenditures were incurred under ALN #20.106 and were not submitted for reimbursement timely. Questioned Costs: None. While invoices were not submitted timely, the costs incurred appear allowable, supported, and related to the approved project scope. The County has since submitted the majority of expenditures for reimbursement. Context: The prior period adjustment was identified during 2024 audit testing. Due to the lack of communication and oversight by the former Airport Manager and Grant Manager, these amounts were not reported in the proper period or submitted for reimbursement timely. The issue was not limited to a single transaction. A prior period adjustment was recognized in the 2024 financial statements to properly reflect these federal expenditures. Cause: The County did not have adequate internal controls in place to ensure timely receipt and tracking of grant-related invoices. The project oversight was insufficient, and the individuals responsible for managing the grant and construction activities failed to communicate expenditures to the finance department timely. Effect: The County materially understated federal expenditures in prior reporting period(s) and did not submit timely reimbursement request for eligible costs. This resulted in a material adjustment to the County’s financial statements and required correction in the current audit period. Recommendations: The County should implement formal internal control procedures to ensure all involved personnel are held accountable for timely communication of incurred costs. All federal grant activities should be monitored on a regular basis by the County and related departments to ensure expenditures are properly recorded and reported. View of Responsible Officials: The County concurs with the finding. The omission of the expenditures was the result of a lack of communication between the former Airport Manager, Grant Manager and finance department. Since discovery, the County has taken steps to ensure improved coordination and documentation of all grant-related expenditures. Project oversight and internal controls will be strengthened through regular reconciliation between project managers and the finance department to ensure timely reporting, submission for reimbursement, and inclusion on the SEFA. The County is in the process of submitting the allowable expenditures for reimbursement and updating internal procedures to prevent future occurrences.
Criteria: 2 CFR §200.510(b) requires the auditee to prepare a schedule of expenditures of federal awards (SEFA). Condition: On the original SEFA provided for the audit, one grant was inaccurately omitted from the schedule and one grant was inaccurately included in the schedule, resulting in restatements of the SEFA. Cause: The grant agreement received bythe Center indicated that no federal funds were being awarded, but the Illinois Comptrollerhadearmarkedthefundsfrom afederalfund.Thegrantthatwasinaccuratelyincludedintheschedulewasa subcontractor agreement which does not need to be included in the SEFA. Effect: The Center was not in compliance with 2 CFR §200.510(b) and the SEFA was inaccurate and not complete. Questioned Costs: None Recommendation: Management should review grant awards and agreements and verify whether the funds received were from federal funds as well update its understanding of what agreements should be included in the SEFA. Views of Responsible Officials: Management agrees with the finding; see corrective action plan.
Condition: On the original SEFA provided for the audit, one grant was inaccurately omitted from the schedule, resulting in a restatement of the SEFA. The SEFA provided for the audit did not include a grant passed through the Hawaii Community Foundation, AL Number 66.203 totaling $79,194. Criteria: Per 2 CFR §200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The schedule must list individual Federal programs by Federal agency and Assistance Listing number, provide the total Federal awards expended, be accurate and complete, and include notes describing the significant accounting policies used in preparing the schedule. Cause: The Organization did not have adequate procedures in place to ensure that all Federal expenditures were identified and included in the SEFA, nor was a comprehensive reconciliation to the general ledger performed prior to submission for audit. Effect: The SEFA as prepared by management was incomplete. This increases the risk that users of the SEFA (including Federal agencies and pass-through entities) could be misled as to the level of Federal funding expended. It also impairs transparency and accountability in Federal award reporting and could result in questioned costs or findings by oversight agencies. Questioned Costs: None Recommendation: We recommend that the Organization implement procedures to ensure that the SEFA is prepared accurately and completely. These procedures should include reconciling the SEFA to the general ledger and grant revenue accounts, confirming completeness by reviewing all grant agreements and funding sources, and establishing a management review process to validate accuracy prior to submission for audit. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding; see corrective action plan.
2024-001—Preparation of the Schedule of Expenditures of Federal Awards and Federal Grants Monitoring Type of Finding (E) Material Weakness in Internal Control Over Compliance of Federal Awards (H) Instance of Material Non-compliance related to Federal Awards Funding Agency U.S. Department of Agriculture (“USDA”) Major Programs Affected Beginning Farmer and Rancher Development Program; Award: BFRDP-2023-49400-40894 (AL 10.311); Period: 09/15/2023-09/14/2026 Partnerships for Climate-Smart Commodities; Award: USDA/NR243A750004G005 (AL 10.937); Period: 11/02/2023 -11/01/2028 Questioned Costs The Questioned Cost are undetermined. Management has estimated the amount for Beginning Farmer and Rancher Development Program; Award: BFRDP-2023-49400-40894 (AL 10.311) to be $42,027 and for Partnerships for Climate-Smart Commodities; USDA/NR243A750004G005 (AL 10.937) to be $33,453. Statement of Condition Quivira implemented a software system (Harvest) to track personnel time spent and expenses for federal programs for the year ended December 31, 2024, but time tracking was not at a level of detail considered sufficient for a properly functioning system of financial reporting. The billing system is not reconciled to the accounting system (QuickBooks) to ensure that all allowable costs are properly tracked, invoiced and reported. This finding appears to be a systemic issue. Also, the Schedule of Federal Awards (“SEFA”) was prepared initially by the Auditor based on revenue rather than expenses due to inconsistencies in recording in the accounting system, which appeared to be a reasonable methodology. Criteria An auditee must prepare a SEFA from its books, including required elements (Assistance Listing, award number, period, pass-through, subrecipient amounts) and maintain financial management systems that allow accurate, timely, and supported reporting (2 CFR 200.510(b); 200.302). Award financial reports (SF-425) must reconcile to the general ledger per award terms. Each grant should have its own general ledger in the accounting system, and the grants billing system should be reconciled regularly with the accounting system. Policies and procedures should be updated to ensure proper reconciliations is done. Cause Quivira has not implemented an effective monthly reconciliation of allowable costs control activity between Harvest and QuickBooks. Effect Quivira was unable to provide a SEFA and a reconciliation to the general ledger. During the audit the billing system was reconciled to the accounting system and multiple errors were discovered. A risk exists that improper tracking and documentation over federal grant awards can lead to instances of noncompliance with grant requirements and inaccurate financial information, which would be used by management, Board of Directors and grantors. Recommendation Quivira should develop and implement a consistent federal grant monitoring process and monthly reconciliation between Harvest and QuickBooks for each federal award. Also, Quivira should improve their policies and procedures by including monthly reconciliations, clearly define the allowable cost under federal rules. Revise budget, if necessary, to reallocate cost, if necessary. Quivira staff should be kept informed about all rules updates under Uniform Guidance. Views of responsible officials and planned corrective actions Quivira Coalition has made efforts to fully comply with federal allowable cost rules, including implementing a compliant time and expense system, implementing a compliant accounting system, consulting with federal program officers, and requesting budget revisions when necessary. However, management agrees that despite its efforts it did not correctly attribute allowable non-personnel and personnel costs to the grants, resulting in errors on the Schedule of Expenditures of Federal Awards (SEFA). Management has analyzed the errors and determined the root causes. Management agrees that the root cause of finding 2024-001 is the discrepancy between the accounting system and time and expenses software system, and that this is material to grant management. After reconciling these discrepancies, as discussed below, management believes the estimated amount for Beginning Farmer and Rancher Development Program; Award: BFRDP - 2023 - 49400 - 40894 (AL 10.311) to be $7,002 and for Partnerships for Climate-Smart Commodities; Award: USDA/NR243A750004G005 (AL 10.937) to be $10,169. Non-Personnel Costs Discrepancies in non-personnel costs were primarily caused by human errors. Management conducted a post-audit reconciliation between the expense tracking system (Harvest) and the general ledger (QuickBooks) which identified the 2024 discrepancies, and Quivira has corrected them. Personnel Costs Discrepancies in labor costs were due to three factors: 1) Quivira Coalition personnel are paid for holidays and paid time off (PTO) and therefore personnel costs include PTO and holiday costs in QuickBooks. However, Quivira’s timekeeping system (Harvest) does not burden federal award personnel costs with PTO and holiday costs making it difficult to reconcile. 2) To allocate personnel costs to a grant, Quivira used the Harvest system. This system calculates a fixed cost rate for each person based on their total annual compensation and expected work capacity and then multiplies this fixed cost rate by the number of hours worked on each grant (as recorded in the Harvest System). However, using fixed cost rates can result in misallocation in situations where personnel work over capacity (e.g. overtime) or under capacity. The appropriate cost allocation approach for salaried employees is to allocate actual personnel costs for a task based on the percentage of total hours worked. 3) Quivira calculated personnel fringe costs based on an estimated hourly fringe rate rather than identifying and allocating actual fringe expenses from QuickBooks. To correct for this material weakness, Quivira Coalition will: Action Step Detail Date Responsible Party Develop a new, compliant method to allocate personnel costs for federal billing and reporting. Stop using the timekeeping system (Harvest) for allocation. The new method must properly reflect actual paid salaries, paid fringe, and actual time spent. 12/31/2025 Accounting Firm Update reporting process to reconcile all costs reported on the SF-425 to the general ledger (instead of the timekeeping system) using the new federal grants billing process. Keep detailed records of the reconciliation. 12/31/2025 Accounting Firm Implement a monthly reconciliation process between the time and expense system (Harvest) and the QuickBooks general ledger to reconcile all non-personnel expenses. 1/31/2026 Operations Director Document the grant management process, including new reporting processes, required reconciliations, monitoring policies, and allowable cost management to ensure consistency across the organization. 2/28/2026 Operations Director Update policies and procedures to require that expenses reported on the SEFA form come directly from the accounting system to ensure this continues. 1/31/2026 Operations Director Update policies and procedures to require an annual reconciliation between the SF-425 and SEFA reports to ensure this continues. This occurs before submitting the SEFA report. 1/31/2026 Operations Director Reconcile all grant programs active in 2024 and 2025 using updated processes and resolve any discrepancies with federal reports or billing. 2/28/2026 Initial Review - Operations Director & Grants Manager Secondary Review & Corrections (if needed) - Accounting Firm Develop a plan to ensure regular and sufficient training on Uniform Guidance tracking regulatory changes, and how to implement changes. Update policies and procedures. 11/30/2025 Operations Director & Executive Director Update policies and procedures to require an additional level of review and approval for SF-425 and SEFA reports and reconciliations for accuracy and completeness before they are submitted. 12/31/2025 Operations Director with final approval from the Executive Director
Finding Reference 2024-002: Inaccurate SEFA Reporting Federal Agency: U.S. Department of Commerce Compliance Requirement: Reporting Federal Program: 11.034 - MBDA Business Center- Capital Readiness Program Grant Award: MB23OBD8020301 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Condition/Context: SEFA provided for audit did not accurately reflect federal expenditures for the Capital Readiness Program as of year-end. Specifically, the SEFA was not reconciled to the underlying financial statements, and differences were noted between reported federal expenditures, receivables, and deferred revenue balances. Criteria: Per 2 CFR 200.510(b), auditees must prepare a SEFA for the period being audited that accurately reflects federal award expenditures and is supported by the accounting records. The SEFA should reconcile to the financial statements. Cause: The SEFA was prepared using incomplete or inaccurate information and was not reconciled to the financial records prior to submission for audit. Effect: Failure to prepare an accurate SEFA increases the risk of audit adjustments, delays in completing the audit, and potential noncompliance with Uniform Guidance reporting requirements. Questioned Costs: None Recommendation: We recommend that CRMSDC implement stronger year-end closing and review procedures to ensure that grant revenue, deferred revenue, and receivables are accurately recorded. SEFA preparation should include a reconciliation process to the general ledger and supporting schedules to ensure completeness and accuracy. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plans section.
Program: Temporary Assistance for Needy Families Assistance Listing No.: 93.558 Federal Grantor: U.S. Department of Health and Human Services Passed-through: County of Sacramento Award No. and Year: DHA-PRTS-NM-07-25-A1; FY 2024 Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards Type of Finding: Material Weakness in Internal Control Over Compliance Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the Organization) must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total federal awards expended (including amounts provided to subrecipients) as determined in accordance with §200.502. In addition, section 200.303 of the Uniform Guidance state that that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts. Condition: During our audit procedures performed over the SEFA and expenditures reported for the Temporary Assistance for Needy Families program we noted the Organization overstated expenditures totaling $138,217. The December 31, 2024 SEFA was corrected for this reporting error. Cause: The Organization did not have adequate internal controls to ensure the Schedule was prepared completely and accurately. Effect: Prior to the correction, expenditures for the Temporary Assistance for Needy Families program were overstated by $138,217. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: No sampling was used. Repeat Finding from Prior Years: No. Recommendation: We the recommend the Organization enhance internal controls to ensure federal expenditures are reported accurately and completely on the SEFA in accordance with the Uniform Guidance. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
2024-007 Reporting Prior Year Finding Number: N/A Year of Finding Origination: 2024 Type of Finding: Internal Control Over Compliance and Compliance Severity of Deficiency: Material Weakness and Modified Opinion Federal Agency: U.S. Department of the Treasury Program: 21.027 COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Award Number and Year: SLFRP3474, 2021 Pass-Through Agency: N/A – Federal Direct Criteria: Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Title 2 U.S. Code of Federal Regulations § 200.510(b) states that the auditee must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements which must include the total federal awards expended as determined in accordance with § 200.502, basis for determining federal awards expended. In addition, the U.S. Department of the Treasury requires recipients of funds to submit Project and Expenditure reports that include, by project, current period obligations, cumulative obligations, current period expenditures, and cumulative expenditures. The frequency of reporting is dependent on the size of the entity and amount of funding received. Condition: During 2024, McLeod County identified an additional $1,302,426 in COVID-19 – Coronavirus State and Local Fiscal Recovery Funds expenditures that were not included in the County’s original SEFA nor in the original population of expenditures provided for audit. In addition, expenditures documented in the County’s annual Project and Expenditure report through March 31, 2025, were understated by $1,515,400, and expenditures documented in the County’s annual Project and Expenditure report through March 31, 2024, were understated by $374,095. Questioned Costs: None. Context: The U.S. Department of the Treasury relies on accurate reporting of program costs to ensure grant funds are spent in accordance with program requirements. McLeod County is required to submit annual Project and Expenditure reports; the County submitted annual reports in both April 2024 and April 2025. Effect: Federal expenditures provided to the auditors were not fairly reported in the SEFA. In addition, the County did not accurately report expenditures on its Project and Expenditure reports as of March 31, 2025, and March 31, 2024. Cause: Due to human error, the County reported funds as obligated instead of expended because of additional projects that are ongoing. Recommendation: We recommend the County implement controls that ensure proper identification of federal expenditures in accordance with program requirements and that federal program reports are accurate. We also recommend the County submit revised Project and Expenditure reports as of March 31, 2025, and March 31, 2024. View of Responsible Official: Concur
2024-003 Schedule of Expenditures of Federal Awards Condition The Organization did not prepare a Schedule of Expenditures of Federal Awards (“SEFA”) for the year ended December 31, 2024. Criteria Per the 2 CFR 200.510(b), auditees must prepare a SEFA for the period covered by the financial statements. Cause The Organization did not have adequate internal controls in place or assign responsibility for preparing the SEFA. Effect Without the SEFA the auditee was not in compliance with the Uniform Guidance reporting requitements. Recommendation We recommend that management establish and implement procedures to ensure that all federal expenditures are identified, tracked, and summarized timely. The auditee should assign responsibility to a qualified individual to prepare the SEFA and reconcile it to the underlying accounting records. Managements Response The Organization has reorganized its management team and accounting functions. We have implemented policies and procedures in order to prepare the SEFA. Status Corrective action has been taken.
Section III – Findings and questioned costs for Federal awards U.S. Department of Homeland Security, Federal Emergency Management Agency Passed through Missouri Department of Public Safety, State Emergency Management Agency Program Name: Disaster Grants – Public Assistance (Presidentially Declared Disasters) Assistance Listing #: 97.036 Finding: 2024 – 001 SIGNIFICANT DEFICIENCY Reporting Condition: During our original audit, the Cooperative initially failed to identify and properly report $878,271 of FEMA aid funding received from the State of Missouri. This error was identified subsequent to the issuance of the report and requires a re-issuance of the related audit reports. The internal control system did not prevent or detect this error to trigger the SEFA preparation process. Cause: The Cooperative's procedures for identifying and reporting federal expenditures were insufficient. The Cooperative finance personnel initially misunderstood the proper period for reporting FEMA disaster assistance expenditures. While the FEMA aid funding was approved by the State on December 20, 2024, with inspection by SEMA completed January 15, 2025, management initially concluded the expenditures should be reported in 2025 based on the cash receipt date. However, the expenditures should have been reported in 2024 when the eligible disaster recovery costs were actually incurred. This timing confusion, combined with the Cooperative's infrequent receipt of federal funding, resulted in the omission from the original 2024 SEFA. Effect: The initial error resulted in the audit report being issued without the required single audit report. While this error has been corrected, the control deficiency increases the risk that future federal awards could be incorrectly reported on the SEFA, potentially resulting in noncompliance with federal reporting requirements and incomplete or inaccurate identification of major programs subject to audit. Questioned Costs: $0 Criteria: 2 CFR 200.510(b) requires that the auditee prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee's financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR 200.502. Additionally, 2 CFR 200.303 requires that non-federal entities establish and maintain effective internal control over Federal awards that provides reasonable assurance that the non-federal entity is managing the awards in compliance with Federal statutes, regulations, and the terms and conditions of the related awards. Recommendation: We recommend the Cooperative implement written procedures for SEFA preparation that include: (1) obtaining and reviewing all award agreements to identify federal funding sources; (2) maintaining a master listing of all awards that identifies the funding source (federal/state/local) and applicable Assistance Listing Numbers; (3) implementing cutoff procedures to ensure federal expenditures are reported in the correct period based on when eligible costs are incurred, not when funds are received from federal systems; and (4) requiring independent review of the SEFA by someone knowledgeable about federal compliance requirements who verifies completeness against award documentation and proper period reporting. We note that the Cooperative's finance office maintains good communication practices with auditors regarding federal funding when they are aware of such awards; therefore, strengthening the internal identification and cutoff processes will enhance the Cooperative's ability to provide complete, accurate, and timely information to auditors about all federal funding sources. Views of responsible personnel and planned corrective actions: Management concurs with this finding. The Cooperative will implement the following corrective actions prior to December 31, 2025: • The CFO will document written procedures for SEFA preparation that specifically address proper period cutoff based on when costs are incurred versus when funds are received. • All current grant agreements will be reviewed to identify federal funding sources and ensure compliance with the single audit threshold. • The CFO will perform quarterly and annual reviews of federal expenditure reporting for completeness, accuracy, and proper period reporting. • Prior to year-end, the CFO will independently review all award documentation to the draft SEFA against all grant documentation to verify completeness and proper period reporting.
Finding 2024-002 Significant Deficiency, Inaccurate Schedule Of Expenditures Of Federal Awards Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance) provides guidance related to preparation and reporting of the Schedule of Expenditures of Federal Awards (the SEFA). 2 CFR Section 200.100 identifies the required elements of the SEFA, and 2 CFR Section 200.510 specifically requires that the SEFA include information on each federal award expended during the year. The City is required to prepare a complete and accurate SEFA and to have a system of internal controls, the design and operation of which allows management or employees in the normal course of performing their assigned functions to prevent, or detect and correct, errors on a timely basis. Condition: The schedule was inaccurate, which led to two errors in the reporting of federal awards. The City did not include federal programs in the amount of $87,605, and the schedule also improperly identified one program with the incorrect assistance listing number, the result of which excluded expenditures from a major program. Cause: The personnel responsible for the preparer and reviewer functions for the grant tracking and reporting process for the year are new to the role and therefore did not have a full understanding of all grant programs and related reporting. This resulted in the errors noted above. Effect: As a result of the errors, the SEFA that was originally presented was incorrect. Inaccurate identification of federal awards may also result in inaccurate identification of compliance requirements, risk assessments, major program determination, materiality determinations and reporting errors. Questioned Costs: None Context: N/A Identification As A Repeat Finding: N/A Recommendation: The City should strengthen its internal controls by implementing additional review processes of its grant programs to ensure the SEFA accurately reflects federal expenditures for the fiscal year. Views Of Responsible Officials And Planned Corrective Action: The City agrees with the finding and has created a corrective action plan for the finding. See the corrective action plan included in this report.
2024-001: Internal Control Over Schedule of Expenditures of Federal Awards Federal Grantor: U.S. Department of the Treasury Federal Assistance Listing Number: 21.027 Program Title: Coronavirus State and Local Fiscal Recovery Funds Pass-through Entity Identifying Number: N/A Award Year: 2024 Questioned Costs: None Criteria: 2 CFR 200.510(b) requires auditees to prepare a schedule of expenditures of federal awards (SEFA) which must report total federal awards expended during the audit period. At a minimum, the schedule must include: expenditures by individual federal program, name of the pass-through entity and identifying number for awards not received directly from the federal government, and the total amount provided to subrecipients from each federal program. The County has not implemented proper internal controls to ensure the completeness and accuracy of the SEFA. Condition: The 2024 SEFA reported by the County in the 2025 annual budget document did not report expenditures of $840,028 for the Coronavirus State and Local Fiscal Recovery Funds program. Cause: The County has not implemented a proper system of internal control over SEFA preparation, such as a reconciliation to underlying accounting records or having a separate individual review of the SEFA for clerical accuracy after it has been prepared. The discrepancy occurred due to management’s oversight. Effect: The SEFA presented for audit did not accurately reflect the County’s actual expenditures of federal awards for the year ended December 31, 2024. Recommendation: We recommend that the County implement internal controls to ensure that the SEFA completely and accurately states the expenditures of federal awards of the County each year.
2024-001: Internal Control Over Schedule of Expenditures of Federal Awards Federal Grantor: U.S. Department of Transportation (DOT), U.S. Department of the Treasury (Treasury), Election Assistance Commission (EAC) Pass-Through Grantor: Missouri Department of Transportation, Missouri Secretary of State Federal Assistance Listing Number: 20.205, 21.027, 90.404 Program Title: Highway Planning and Construction, Coronavirus State and Local Fiscal Recovery Funds, HAVA Election Security Grants Pass-through Entity Identifying Number: BRO-R099(001), BRO-B099(23), RRP-000S(581) Award Year: 2024 Questioned Costs: None Criteria: 2 CFR 200.510(b) requires auditees to prepare a schedule of expenditures of federal awards (SEFA) which must report total federal awards expended during the audit period. At a minimum, the schedule must include: expenditures by individual federal program, name of the pass-through entity and identifying number for awards not received directly from the federal government, and the total amount provided to subrecipients from each federal program. Condition: The SEFA reported by the County in the 2025 annual budget document did not include all federal expenditures. Discrepancies in amounts reported on the 2024 SEFA and amount supported by underlying accounting records are summarized as follows: Cause: The County has not implemented a proper system of internal control over SEFA preparation, such as a review of underlying accounting records to ensure all federal expenditures have been included. Effect: The SEFA presented for audit did not accurately reflect the County’s actual expenditures of federal awards for the year ended December 31, 2024. Recommendation: We recommend that the County implement internal controls to ensure that the SEFA completely and accurately states the expenditures of federal awards of the County each year.
2024-004: Internal Control Over Schedule of Expenditures of Federal Awards Federal Grantor: U.S. Department of the Treasury Pass-Through Grantor: N/A Federal Assistance Listing Number: 21.027 Program Title: Coronavirus State and Local Fiscal Recovery Funds Pass-through Entity Identifying Number: N/A Award Year: 2024 Questioned Costs: None Criteria: 2 CFR 200.510(b) requires auditees to prepare a schedule of expenditures of federal awards (SEFA) which must report total federal awards expended during the audit period. At a minimum, the schedule must include: expenditures by individual federal program, name of the pass-through entity and identifying number for awards not received directly from the federal government, and the total amount provided to subrecipients from each federal program. Condition: The SEFA reported by the County in the 2024 annual budget document underreported expenditures of the Coronavirus State and Local Fiscal Recovery Funds program (ALN 21.027) by $1,184,214. Cause: The County has not implemented a proper system of internal control over SEFA preparation, such as a reconciliation to underlying accounting records or having a separate individual review the SEFA for clerical accuracy after it has been prepared. Effect: The SEFA presented for audit did not accurately reflect the County’s actual expenditures of federal awards for the year ended December 31, 2024. Recommendation: We recommend that the County implement internal controls to ensure that the SEFA completely and accurately states the expenditures of federal awards of the County each year.
2024-003: Internal Control Over Schedule of Expenditures of Federal Awards Federal Grantor: U.S. Department of Justice (DOJ), U.S. Department of Transportation (DOT), U.S. Department of the Treasury (Treasury), Executive Office of the President (EOP) Pass-Through Grantor: Missouri Department of Transportation, University of Central Missouri, Missouri Secretary of State, Missouri State Highway Patrol Federal Assistance Listing Number: 16.575, 20.205, 20.607, 20.616, 21.027, 95.001 Program Title: Crime Victim Assistance, Highway Planning and Construction, Alcohol Open Container Requirements, National Priority Safety Programs, Coronavirus State and Local Fiscal Recovery Funds, High Intensity Drug Trafficking Area Program Pass-through Entity Identifying Number: BRO-R071(11), BRO-R071(12), 24-154-AL-049, 25-ENF-03-078, 24-M2HVE-05-032, SLFRP4542-CJMI030, G23MW0001A-QQ Award Year: 2023 and 2024 Questioned Costs: None Criteria: 2 CFR 200.510(b) requires auditees to prepare a schedule of expenditures of federal awards (SEFA) which must report total federal awards expended during the audit period. At a minimum, the schedule must include: expenditures by individual federal program, name of the pass-through entity and identifying number for awards not received directly from the federal government, and the total amount provided to subrecipients from each federal program. Condition: The SEFA reported by the County in the 2024 and 2025 annual budget documents contained errors in amounts of federal expenditures reported. This finding was noted in the prior audit as item 2020-006. Discrepancies in amounts reported on the 2023 SEFA and amount supported by underlying accounting records are summarized as follows: Discrepancies in amounts reported on the 2024 SEFA and amounts supported by underlying accounting records are summarized as follows: Cause: The County has not implemented a proper system of internal control over SEFA preparation, such as a reconciliation to underlying accounting records or having a separate individual review the SEFA for clerical accuracy after it has been prepared. Reasons for discrepancies in individual programs varied. Effect: The SEFA presented for audit did not accurately reflect the County’s actual expenditures of federal awards for both the years ended December 31, 2023 and 2024. Recommendation: We recommend that the County implement internal controls to ensure that the SEFA completely and accurately states the expenditures of federal awards of the County each year.
Finding 2024-002: Information on the Federal Program: Compliance Requirements: Other—Schedule of Expenditure of Federal Awards Preparation Type of Finding: Material Noncompliance and Material Weakness in Internal Control over Compliance. Criteria: 2 CFR 200.510 indicates that the auditee must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements which must include the total federal awards expended as determined in accordance with 200.502 Basis for Determining Federal Awards Expended. Per 2 CFR 200.502, the determination of when a federal award is expended should be based on when the activity related to the federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with federal statutes, regulations, and the terms and conditions of federal awards, such as: expenditure/expense transactions associated with awards. In addition, 2 CFR Part 200.303 requires the program establish and maintain effective internal controls over federal awards that provide reasonable assurance of compliance with federal statutes, regulations, and the terms and conditions of federal awards. Condition: The Organization failed to prepare a complete and accurate SEFA for the year ended December 31, 2024. The SEFA is a required supplementary schedule that provides detailed information on all federal awards received and expended during the fiscal year, in accordance with 2 CFR 200.510. Cause: The noncompliance resulted from a deficiency in the Organization’s internal controls. The Organization does not have established policies and procedures to ensure all federal awards are properly identified, tracked, and included in the SEFA preparation process. Effect or Potential Effect: Due to the control deficiencies described above, if not for auditor assistance, inaccurate expenditures result in a high risk that material noncompliance with federal regulations could occur and not be detected and corrected in a timely manner; inaccurate reporting to federal agencies on the Organization’s federal expenditures; and persistent noncompliance can lead to potential loss of funding. Questioned costs: No questioned costs were identified as a result of this compliance finding. Context: The Organization mistakenly omitted to report expenditures of federal award expenditures on an accrual basis under the Sexual Risk Avoidance, ALN 93.060, and Title V Sexual Risk Avoidance Education Program (Discretionary Grants), ALN 93.787. Recommendation: We recommend that the Organization establish formal procedures to ensure SEFA preparation along with all federally funded contracts included in the SEFA as expenditures; implement a robust process to track all federal awards under government auditing standards, provide training on Uniform Grant Guidance, including SEFA preparation; perform management review to ensure the SEFA is accurate, complete, and prepared in a timely manner. Views of responsible officials and planned corrective actions: Management acknowledges the omission of the auditee’s prepared SEFA. Management is committed to properly preparing the SEFA, and to address this oversight, management will identify trainings for accounting personnel related to SEFA reporting and for those reviewing the schedule, to ensure its accuracy.
Finding 2024-001: Reportable finding considered a significant deficiency - Inaccurate and Incomplete Schedule of Expenditures of Federal Awards (SEFA) and Delay in Reporting Program names: ARPA Workforce development and Workforce Innovation and Opportunity Act (WIOA) Adult 24-25 - Cluster Assistance Listings and Award Number: 21.027 (24-25 ACWDB-MP-01) and 17.258 (24343) Federal awarding agency: United States Department of the Treasury for American Rescue Plan Act (ARPA) of 2021 and United States Department of Labor Pass-through Entities: Alameda County Workforce Development Board and City of Oakland Workforce Development Board Criteria: In accordance with 2 CFR 200.510(b), the auditee must prepare a complete and accurate Schedule of Expenditures of Federal Awards (SEFA) that includes the total federal awards expended for each federal program, the assistance listing number (ALN), the name of the federal agency, and the pass-through entity identifying number. Accurate SEFA reporting is essential to support the auditor’s responsibility under 2 CFR 200.518 major program determination and for federal oversight. In addition this error resulted in a delay in financial reporting. 2 CFR §200.512(b) requires that the Uniform Guidance report be submitted "no later than 30 calendar days after receipt of the auditor’s report or nine months after the end of the audit period," whichever comes first. Timely reporting is essential for compliance with federal grant requirements and for maintaining eligibility for future funding. Condition: The Organization failed to include two federal pass-through awards received from state and local governmental entities in the current years’ SEFA. These awards were only identified as federal during the current audit year. After additional inquiry, they were determined to fall under ALN 21.027 and 17.258. Cause: There were deficiencies in the Organization’s internal controls over SEFA preparation, specifically in identifying, classifying, and documenting pass-through federal awards. The absence of award documentation and misclassification of the assistance listing number further indicate inadequate review and verification procedures. Effect: Incomplete and inaccurate SEFA reporting may lead to noncompliance with Uniform Guidance requirements and increases the risk of omitted or misclassified programs subject to audit. Misreporting ALNs may also hinder proper audit coverage and oversight by federal and pass-through entities. In addition the error resulted in a delay in financial reporting. Repeat finding: This is not a repeat finding. Questioned costs: There are no questioned costs associated with this finding. Perspective: This issue affected two federal awards and represents a systemic control issue over SEFA preparation. There is a reasonable possibility that similar issues could recur if not addressed. Recommendation: We recommend that the Organization: Implement procedures to require written documentation (e.g., subaward agreements) for all federal pass-through funding received. Enhance internal controls over the SEFA preparation process to ensure federal programs are accurately identified, classified, and reported, including verification of ALNs and funding sources. Designate responsibility within the finance team for verifying the federal nature of all awards and ensure ongoing training on SEFA and Uniform Guidance requirements.
2024-001: Internal Control Over Schedule of Expenditures of Federal Awards Federal Grantor: U.S. Department of Transportation, U.S Department of the Treasury Pass-Through Grantor: Missouri Department of Transportation Federal Assistance Listing Number: 20.205, 21.027 Program Title: Highway Planning and Construction; Coronavirus State and Local Fiscal Recovery Funds Pass-through Entity Identifying Number: TAP-9900(144) Award Year: 2024 Questioned Costs: None Criteria: 2 CFR 200.510(b) requires auditees to prepare a schedule of expenditures of federal awards (SEFA) which must report total federal awards expended during the audit period. At a minimum, the schedule must include: expenditures by individual federal program, name of the pass-through entity and identifying number for awards not received directly from the federal government, and the total amount provided to subrecipients from each federal program. Condition: The SEFA reported by the County in the 2024 annual budget document contained errors in amounts of federal expenditures reported. Discrepancies in amounts reported on the 2024 SEFA and amounts supported by underlying accounting records are summarized as follows: Cause: The County has not implemented a proper system of internal control over SEFA preparation, such as a reconciliation to underlying accounting records or having a separate individual review the SEFA for clerical accuracy after it has been prepared. Reasons for discrepancies in individual programs varied. Effect: The SEFA presented for audit did not accurately reflect the County’s actual expenditures of federal awards for the year ended December 31, 2024. Recommendation: We recommend that the County implement internal controls to ensure that the SEFA completely and accurately states the expenditures of federal awards of the County each year.
2024-002: Internal Control Over Schedule of Expenditures of Federal Awards Federal Grantor: U.S. Department of the Interior (DOI), U.S. Department of the Treasury (Treasury), U.S. Department of Health and Human Services (HHS), and U.S. Department of Homeland Security (DHS) Pass-Through Grantor: Missouri Department of Public Safety, Missouri Department of Health and Senior Services Federal Assistance Listing Number: 15.226, 15.659, 21.027, 21.032, 93.323, 97.137 Program Title: Payments in Lieu of Taxes, National Wildlife Refuge Fund, Coronavirus State and Local Fiscal Recovery Funds, Local Assistance and Tribal Consistency Fund, Epidemiology and Laboratory Capacity for Infectious Diseases, State and Local Cybersecurity Grant Program Pass-through Entity Identifying Number: N/A Award Year: 2023 and 2024 Questioned Costs: None Criteria: 2 CFR 200.510(b) requires auditees to prepare a schedule of expenditures of federal awards (SEFA) which must report total federal awards expended during the audit period. At a minimum, the schedule must include: expenditures by individual federal program, name of the pass-through entity and identifying number for awards not received directly from the federal government, and the total amount provided to subrecipients from each federal program. This finding was noted in the prior audit for the year ending December 31, 2022 as item 2022-005. Condition: The SEFA reported by the County in the 2024 and 2025 annual budget documents contained errors in amounts of federal expenditures reported. Discrepancies in amounts reported on the 2024 SEFA and amounts supported by underlying accounting records are summarized as follows: Discrepancies in amounts reported on the 2023 SEFA and amounts supported by underlying accounting records are summarized as follows: Cause: The County has not implemented a proper system of internal controls over SEFA preparation, such as reconciliation to underlying accounting records or having a separate individual review the SEFA for clerical accuracy after it had been prepared. The County believed that federal grant reimbursements did not have to be reported on the SEFA. Effect: The SEFA presented for audit did not accurately reflect the County’s actual expenditures of federal awards for both the years ended December 31, 2024 and 2023. Recommendation: We recommend that the County implement internal controls to ensure that the SEFA completely and accurately states the expenditures of federal awards of the County each year.
Criteria: Per guidance: 2CFR 200.510(b) – Under 2 CFR §200.510(b), the Uniform Guidance mandates that auditees prepare a SEFA that accurately reflects federal award expenditures. Additionally, 2 CFR Part 200 Subpart F outlines the required components that must be included in the SEFA. Condition: During the audit, we noted that the SEFA did not include required information around identification of passthrough information which is required under Uniform Guidance. We also noted in our testing that the SEFA amount reported was overstated based on the improper identification of federal versus state funds received. The amount reported was determined to include state funds as well as federal funds. Cause: Management does not have sufficient internal controls to ensure the accuracy and completeness of the Schedule of Expenditures of Federal Awards. During performance of audit procedures, we noted that the identification of federal funds was miscalculated based on a lack of information provided by the pass-through agency. We find that several counties failed their responsibilities as a pass-through agency to provide timely federal award information to their subrecipient, Koinonia Foster Homes, Inc. We also noted that the SEFA was not reflecting the passthrough entity information which is required in which the Agency had the information available in order to do so. Effect: The use of incomplete or incorrect information on the SEFA can result in the improper identification of major programs and related compliance requirements. Management subsequently corrected the SEFA to reflect accurate expenditures of federal awards incurred in 2024. Recommendation: We recommend that the management and those charged with governance review the Uniform Guidance requirements in regards to SEFA reporting. Management cannot rely upon each respective County to proactively assist Koinonia Foster Homes, Inc. to produce an accurate SEFA. We recommend that in addition to correspondence with each County throughout the year, they obtain California state issued letters that are published on the website, that present the annual federal to state ratios of Foster Care – Title IV-E funds that can be used to identify federal funds received. We also recommend that one or more levels of review and approval of the SEFA be done by a member of management to ensure accuracy.
Assistance Listing, Federal Agency, and Program Name ALN 14.218, U.S. Department of Housing and Urban Development, Entitlement Grants Cluster (CDBG), Community Development Block Grants/Entitlement Grants and ALN 20.507, U.S. Department of Transportation, Federal Transit Cluster, Federal Transit Formula Grants Federal Award Identification Number and Year All grants under ALN Pass through Entity N/A Finding Type Material weakness Repeat Finding No Criteria Per 2 CFR Section 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 determined in accordance with Section 200.502. Condition The CDBG Cluster and Federal Transit Cluster expenditures on the schedule of expenditures of federal awards (SEFA) initially presented for audit were not complete and accurate. Questioned Costs None If Questioned Costs are Not Determinable, Description of Why Known Questioned Costs Were Undetermined or Otherwise Could not be Reported Not applicable Identification of How Questioned Costs Were Computed Not applicable Context The CDBG Cluster expenditures were overstated by $792,426 and the Federal Transit Cluster expenditures were overstated by $365,634. The final SEFA has been corrected. Cause and Effect Controls in place did not ensure the SEFA was complete and accurate and as a result, the SEFA needed to be adjusted for two federal clusters. This did not impact major program determination. Recommendation The City should implement a process to ensure the expenditures reported on the SEFA are complete and accurate. Views of Responsible Officials and Corrective Action Plan Due to turnover and the loss of a long term employee new processes were implemented to prepare reporting and documentation processes for the Federal Transit Cluster. Written Standard Operating Procedures have been generated and will be updated as necessary. Reporting and draw processes have been updated to include written signatures of approval for the documentation. The staff in transit and finance work closely together to ensure the completeness of records. City of Greeley will also be organizing a formalized grants team that will be dedicated to all grant activities including the SEFA and correcting the prior staffing insufficiencies.
Criteria – Uniform Guidance (2 CFR §200.510(b)) requires auditees to prepare a SEFA that is accurate, complete, and supported by the accounting records. Condition and Description – The Organization did not prepare a complete and accurate Schedule of Expenditures of Federal Awards (SEFA) as required by Uniform Guidance. Certain federal awards expended during the year were omitted, and amounts reported did not reconcile to the accounting records, resulting in an incomplete representation of federal expenditures subject to audit. Questioned Costs – Unknown. Cause/Effect –. Controls over SEFA preparation were insufficient to ensure all federal awards were identified and reconciled to the accounting records. As a result, certain expenditures were omitted or misstated, increasing the risk of incomplete or inaccurate reporting under Uniform Guidance.
2024-001: Internal Controls Over SEFA Preparation Federal Assistance Listing Number: 21.027 Name of Program or Cluster: Coronavirus State and Local Fiscal Recovery Funds Agency: U.S. Department of the Treasury Criteria Per 2 CFR §200.510(b), non-federal entities that expend $750,000 or more in federal awards during the fiscal year are required to prepare a SEFA that includes accurate and complete information about all federal awards expended. The Uniform Guidance also emphasizes the importance of internal control systems over compliance and reporting, as outlined in 2 CFR §200.303. Entities must establish and maintain effective internal controls to ensure compliance with federal statutes, regulations, and the terms and conditions of federal awards Condition Life Management, Inc. (LMI) does not appear to have implemented sufficient internal controls to ensure the complete and accurate preparation of the Schedule of Expenditures of Federal Awards (SEFA) for the year ended December 31, 2024. Although LMI’s SEFA preparation memo states that the Chief Financial Officer (CFO) is responsible for compiling the SEFA using information from the accounting system and supporting grant documentation, in practice, we noted that the entity relied on an external entity to provide essential grant documentation necessary for SEFA preparation. Additionally, the SEFA/SESFA provided appeared to be outdated and not reflective of current-year grant activity. Cause The absence of a fully developed control structure and oversight mechanism appears to have contributed to reliance on external or related-party sources for preparing SEFA-related documentation. This suggests a lack of staff with adequate skills, knowledge, and experience (SKE) necessary for SEFA preparation. Repeat Finding No Recommendation We recommend that Life Management, Inc. strengthen its internal control processes over SEFA preparation. This may include: • Providing training to appropriate staff to ensure they have the requisite skills, knowledge, and experience to independently prepare the SEFA in accordance with federal requirements. • Engaging or hiring qualified personnel with federal grant accounting expertise to oversee the SEFA preparation process. • Reducing reliance on external or related parties for documentation by maintaining a centralized, internal repository of grant agreements and related records. Views of Responsible Officials See Corrective Action Plan
Criteria or specific requirement (including statutory, regulatory, or other citation): The City must prepare a SEFA that is accurate and complete in accordance with 2 CFR 200.510. Condition and context: The City did not prepare a SEFA that was accurate and complete in accordance with Uniform Guidance, as two programs were reported at incorrect amounts. Cause: Lack of internal controls to ensure accurate preparation and review of the SEFA. Effect or potential effect: The SEFA required significant adjustment to be complete and accurate. Recommendation: The City should implement policies and procedures to ensure timely and accurate preparation of the SEFA. Views of responsible officials: As noted in the corrective action plan, management agrees with this finding.
Finding 2024-003: Inaccurate Reporting of SLFRF Expenditures and Fiscal Year End Federal Program: Coronavirus State and Local Fiscal Recovery Funds (SLFRF) Assistance Listing Number (ALN): 21.027 Federal Agency: U.S. Department of the Treasury Type of Finding: Compliance and significant deficiency in internal control over compliance Criteria: Per Uniform Guidance (2 CFR 200.510(b) and 2 CFR 200.516), recipients must accurately report expenditures and obligations in required annual compliance reports. Reports must also reflect the correct fiscal year end date as required by federal and state reporting standards. Context: Morgan County is a recipient of SLFRF funding and is required to submit accurate annual compliance reports reflecting actual expenditures and the correct fiscal year end. For the reporting period ending March 31, 2025, the County elected the $10 million standard allowance for revenue loss and was required to report all SLFRF expenditures incurred during the year ended December 31, 2024. Condition: The County’s SLFRF compliance report for the year ended December 31, 2024 included several clerical errors including incorrectly reporting there were $0 in current period expenditures rather than the $1,660,202 included on the Schedule of Expenditures of Federal awards as well as incorrectly listing the fiscal year end date as December 31, 2023. Cause: The errors appear to be due to insufficient oversight in preparing the annual compliance report due to staffing issues within the County. Effect: The inaccurate reporting resulted in noncompliance with federal and state reporting requirements. This may impact the transparency and accountability of SLFRF fund usage. Questioned Costs: None Recommendation: Morgan County should implement procedures to ensure accurate reporting of expenditures and correct fiscal year end dates in all future SLFRF compliance reports. The County should ensure that all future reports are reconciled to actual activity and comply with SLFRF and Uniform Guidance requirements. Views of Responsible Officials: Management concurs with the finding and will address the issue as outlined in the corrective action plan included in this report
Internal Control over Compliance and Compliance with Reporting (Preparation of the Schedule of Expenditures of Federal Awards (SEFA)) ALN: 10.904, Milk River Project ALN: 10.923, Stream Restoration and Bridge Replacement for St. Mary Siphon Failure ALN: 15.U01, Replacement of St. Mary and Hallls Coulee Siphons on St. Mary Canal CRITERIA: The Code of Federal Regulations (CFR) Section §200.510(b) states in part: "The auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee's financial statements which must include the total Federal awards expended as determined in accordance with CFR Section §200.502 Basis for determining Federal awards expended." The schedule must provide total Federal awards expended for each individual Federal program. CFR 200.302(b)(1) requires that the nonfederal entity must identify in its accounts and on the schedule of expenditures of federal awards all federal awards received and expended, as well as the federal programs under which they were received. Federal program and award identification must include, as applicable, the Assistance Listing program title and number, the federal award identification number and year, the name of the federal agency, and the name of the pass-through entity, if any. CONDITION: The ALN 10.923, Stream Restoration and Bridge Replacement for St. Mary Siphon Failure, was left off the prepared SEFA. Amounts reported for ALN 10.904 and ALN 15.U01 did not agree to the accounting records. CONTEXT: The SEFA was misstated as follows: • Understated for ALN 10.904 by $196,980; • Understated for ALN 10.923 by $105,977; and • Overstated for ALN 15.U01 by $1,978,224. The net effect was an overstatement of $1,675,267 for total federal expenditures. EFFECT: The SEFA provided was not complete and accurate. QUESTIONED COSTS: None CAUSE: The internal controls for the preparation of the SEFA and review of the SEFA were not present to ensure the SEFA was complete and accurate. RECOMMENDATION: We recommend the MRJBOC prepare written procedures on how to put together the SEFA and strengthen internal controls to ensure all federal awards are included on the SEFA. We also recommend that the SEFA be reviewed by someone other than the preparer for completeness and accuracy prior to providing to the auditor. MRJBOC RESPONSE: MRJBOC acknowledges the deficiencies identified in the preparation and review of the Schedule of Expenditures of Federal Awards (SEFA). During 2024, the organization experienced a significant increase in federal funding activity related to emergency response and infrastructure replacement projects. The rapid expansion of federal programs, addition of funds and reporting requirements exceeded existing internal documentation and review processes. To strengthen compliance controls and ensure SEFA accuracy in future reporting periods, MRJBOC will implement the following corrective actions: • Develop and formalize written SEFA preparation procedures, including grant identification, ALN verification, and reconciliation to general ledger balances. • Establish a dual-review process in which the SEFA is reviewed and approved by a party independent from the preparer prior to submission to auditors. • Maintain a centralized federal grant tracking log that includes award numbers, funding sources, drawdowns, and cumulative expenditures. These measures will improve internal control over federal reporting, enhance accuracy, and ensure compliance with federal audit requirements.
Criteria: 2 CFR Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Awards Requirements, Standards for Financial and Program Management, and §200.302 (b), Financial Management. The recipients financial management system must provide for identification, in its accounts, of all federal awards received and expended and the federal program under which they were received. Federal program and federal award identification must include, as applicable, the federal assistance listing title and number, federal award identification number, name of the federal agency, and name of the pass-through entity, if any. Additional Criteria: 2 CFR Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart F – Audit Requirements, §200.510, Financial Statements. Schedule of Expenditures of Federal Awards – The auditee also must prepare a schedule of expenditures of federal awards for the period covered by the auditee’s financial statements, which must include the total federal awards expended, as determined in accordance with §200.502, Basis for Determining Federal Awards Expended. At a minimum, the schedule must provide total federal awards expended for each individual federal program and the federal assistance listing number or other identifying number when the federal assistance listing information is not available. For a cluster of programs, also provide the total for the cluster. Condition: PCRI did not maintain a complete schedule of expenditures of federal awards. Cause: PCRI did not adequately track which government grants were federally-funded, resulting in an incomplete schedule of expenditures of federal awards. Effect: Failure to prepare an accurate and complete schedule of expenditures of federal awards results in noncompliance with 2 CFR Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Awards Requirements, Standards for Financial and Program Management, §200.302, Financial Management, and Subpart F – Audit Requirements, §200.510, Financial Statements. Recommendation: We recommend that PCRI document and implement policies and procedures to ensure the schedule of expenditures of federal awards is accurate and complete in accordance with 2 CFR Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Awards Requirements, Standards for Financial and Program Management, §200.302, Financial Management, and Subpart F – Audit Requirements, §200.510, Financial Statements, in order to obtain accurate calculations of major federal programs for the Single Audit and to ensure that PCRI is in compliance with all of the reporting requirements as to identify the source and application of funds for federally-funded activities.
Improper Preparation of the Schedule of Expenditures of Federal Awards Condition: The Agency did not properly prepare the Schedule of Expenditures of Federal Awards ("SEFA") as required by 2 CFR 200.510(b). The Agency did not initially prepare a SEFA as it was unaware that it had expended $750,000 in federal awards, thereby triggering the requirement for a Single Audit. The Chief Financial Officer was unaware of which grants qualified as Federal awards, especially those passed through the State or County. The Chief Financial Officer was also unaware of how to prepare a SEFA once the federal awards had been determined. Criteria: Under 2 CFR 200.510(b), an auditee that expends the federal award threshold in a fiscal year must prepare a SEFA for the period covered by its financial statements, including each federal program's assistance listing number, federal agency, pass-through entity, if applicable, and total federal expenditures by program. The SEFA is required supplementary information used as the basis for planning and conducting the Single Audit, including the determination of major programs. Cause: The condition resulted from insufficient knowledge and training of accounting staff and management regarding SEFA requirements and the Single Audit process. Management had not established detailed procedures, including reconciliation of the SEFA to the general ledger and grant records, or a formal review process to ensure that all required elements and programs were included and properly presented. Effect: Because the SEFA was not initially completed, there was a risk that one or more federal programs would not be selected and tested as part of the Single Audit, potentially resulting in noncompliance with Uniform Guidance audit requirements. Inaccurate reporting of federal expenditures can affect the determination of major programs, potentially lead to questioned costs, and may cause federal agencies to or pass-through entities to view the auditee as noncompliant with Single Audit reporting requirements. The ARPA grant under Assistance Listing Number 21.027 (Coronavirus State and Local Fiscal Recovery Funds) was identified as the major program for testing. However, we later discovered an additional county-funded grant under the same Assistance Listing number that had not previously been communicated. This omission resulted in an initial testing sample from an incomplete population requiring additional procedures to correct the impact on the Single Audit. Questioned Cost: None noted as a result of audit procedures performed. Recommendation: Management should develop and implement written procedures for preparing the SEFA that: • Identify all active federal awards and related pass-through awards from grant agreements and award notices. • Reconcile SEFA amounts to the general ledger and the grant reporting records. • Ensure that required elements (federal agency, Assistance Listing number, pass-through entity, and total expenditures) are accurately presented for each program. • Provide for a secondary review by someone knowledgeable about federal grant requirements and Single Audit rules prior to finalizing the SEFA. Management Response: We agree with the findings in the audit report and have developed a Corrective Action Plan to address each item promptly. This has been a challenging year for the organization, including turnover in the Chief Financial Officer ("CFO") position and the fact that this was our first Single Audit due to increased federal funding related to COVID-19 programs. These factors contributed to delays in audit readiness, gaps in technical accounting for grants, and weaknesses in internal controls over financial reporting and federal award reporting. We have implemented a comprehensive plan to address these challenges and will be hiring a new CFO in the first quarter of 2026.
2 CFR Subpart F § 200.510(b) requires the auditee prepare a Schedule of Expenditures of Federal Awards (the Schedule) for the period covered by the City’s financial statements which must include the total federal awards expended as determined in accordance with § 200.502. At a minimum, the schedule must: (1) List individual Federal programs by Federal agency. (2) For Federal awards received as a subrecipient, the name of the pass-through entity and identifying number assigned by the pass-through entity must be included. (3) Provide total Federal awards expended for each individual Federal program and the AL number or other identifying number when the AL number information is not available. (4) Include the total amount provided to subrecipients from each Federal program. (5) For loan or loan guarantee programs described in § 200.502 Basis for determining Federal awards expended, paragraph (b), identify in the notes to the schedule the balances outstanding at the end of the audit period. (6) Include notes that describe the significant accounting policies used in preparing the schedule, and note whether or not the auditee has elected to use the 10 percent de minimis cost rate as covered in § 200.414 Indirect (F&A) costs. The City’s internal control procedures identified and properly recorded $141,051 of Coronavirus relief funds and $577,081 of Highway Planning and Construction pass-through expenses for PID #113961 for recording in their Schedule of Federal Awards Expenditures (Schedule). The City did not identify $381,346 of pass-through expenses for PID #115721 in the Schedule related to the Highway Planning and Construction Funds. Adjustments, to which management have agreed, are reflected in the accompanying Schedule. Noncompliance with grant requirements as well as errors and omissions on the Schedule of Expenditures of Federal Awards could have an adverse effect on future grant awards by the awarding agencies in addition to an inaccurate assessment of major federal programs that would be subjected to audit.
Finding 2024-003 – All Federal Programs – Significant Deficiency Deficiency in Internal Controls over the Preparation of the Schedule of Expenditures of Federal Awards (SEFA) Criteria: 2 CFR section 200.510(b) requires recipients of federal awards to prepare a complete and accurate Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements. The Uniform Guidance also requires that management establish and maintain effective internal controls over the preparation of the SEFA to ensure its accuracy and completeness. Condition: During our audit, we noted that the Organization did not have adequate internal controls in place to ensure the accuracy of the SEFA. Specifically, there was no documented review process to verify that all federal expenditures were properly identified, classified, and reported under the correct Assistance Listing numbers. As a result, a material adjustment was required to correct the SEFA for balance that were not from federal sources as well as correct the amounts reported. There was also certain federal expenditures reported under an incorrect Assistance Listing number. Cause: The deficiency occurred because the Organization had not developed or implemented a formal review procedure for the preparation of the SEFA. Finance staff responsible for preparing the SEFA did not coordinate with grant reporting personnel to ensure the completeness and accuracy of the information included in the schedule. Effect: The lack of appropriate internal controls over the preparation of the SEFA resulted in the initial omission and misclassification of federal expenditures. This could lead to incomplete or inaccurate reporting of federal awards, potentially resulting in noncompliance with federal requirements and affecting the determination of major programs for audit purposes. Questioned Costs: None noted. Recommendation: We recommend that the Organization develop and implement formal internal control procedures over the preparation of the SEFA. This should include a documented review process to ensure that all federal expenditures are accurately identified, classified, and reported under the correct Assistance Listing numbers. Finance staff should coordinate with grant reporting personnel to verify the completeness and accuracy of the SEFA prior to its finalization.
ALN 21.027 Finding #2024‐002 Incomplete Schedule of Expenditures of Federal Awards Repeat Finding: No Condition: The auditee’s Schedule of Expenditures of Federal Awards (SEFA) for the year ended December 31, 2024 did not include all federal awards. Specifically, two federal pass‐through grants (ALN# 21.027) in the aggregate amount of $1,035,393 were omitted. Criteria: Per 2 CFR §200.510(b), auditees must prepare a SEFA that is complete and accurate for the period covered by the financial statements. The SEFA must list individual federal programs by Federal agency, identify pass‐through entities, and present total federal awards expended. Government Auditing Standards require auditors to assess whether internal controls over federal reporting are designed and implemented effectively to ensure completeness and accuracy. Cause: The omission occurred because the auditee did not have adequate internal control procedures to ensure all federal awards were identified and reconciled to supporting accounting records. Effect: The omission resulted in the SEFA being materially misstated prior to auditor detection. This could have impacted the determination of major programs and the scope of the audit. Failure to prepare a complete SEFA increases the risk that federal oversight agencies and pass‐through entities may not have reliable information for monitoring federal funds. Perspective Information: The omitted grants totaled $1,035,393 of the Organization’s total federal expenditures for the year ended December 31, 2024. This indicates a systemic deficiency in the Organization’s SEFA preparation process. Recommendation: We recommend that management strengthen its internal control process over SEFA preparation. Specifically, management should establish procedures to: · Reconcile the SEFA to the general ledger and grant agreements, · Review grant award schedules with program and finance staff to ensure completeness, and · Implement a secondary review of the SEFA prior to submission. Reporting Views of Responsible Officials: The Organization agrees with the finding. The Organization was unaware that passthrough funds from federal sources are required to be presented on the SEFA and has implemented procedures to ensure all grants are evaluated to ensure the SEFA is complete.
2024-001: Internal Control Over Schedule of Expenditures of Federal Awards Federal Grantor: U.S. Department of Transportation (DOT), U.S. Department of the Treasury (Treasury), Election Assistance Commission (EAC) Pass-Through Grantor: Missouri Department of Transportation, Missouri Secretary of State Federal Assistance Listing Number: 20.205, 21.027, 90.404 Program Title: Highway Planning and Construction, Coronavirus State and Local Fiscal Recovery Funds, HAVA Election Security Grants Pass-through Entity Identifying Number: BRO-R099(001), BRO-B099(23), RRP-000S(581) Award Year: 2024 Questioned Costs: None Criteria: 2 CFR 200.510(b) requires auditees to prepare a schedule of expenditures of federal awards (SEFA) which must report total federal awards expended during the audit period. At a minimum, the schedule must include: expenditures by individual federal program, name of the pass-through entity and identifying number for awards not received directly from the federal government, and the total amount provided to subrecipients from each federal program. Condition: The SEFA reported by the County in the 2025 annual budget document did not include all federal expenditures. Discrepancies in amounts reported on the 2024 SEFA and amount supported by underlying accounting records are summarized as follows: Cause: The County has not implemented a proper system of internal control over SEFA preparation, such as a review of underlying accounting records to ensure all federal expenditures have been included. Effect: The SEFA presented for audit did not accurately reflect the County’s actual expenditures of federal awards for the year ended December 31, 2024. Recommendation: We recommend that the County implement internal controls to ensure that the SEFA completely and accurately states the expenditures of federal awards of the County each year.
2024-001 - SEFA REPORTING Federal Program Information: Federal Agency and Program Name - National Endowment for the Humanities Promotion of the Humanities Federal/State Partnership Grant Number: SO-289836-23 Federal Assistance Listing Number 45.129 Criteria: 2 CFR 200.303 requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non- Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” 2 CFR 200.510(b) states that “the auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR 200.502.” Condition: The Council’s internal controls are not adequate to ensure the Schedule of Expenditures of Federal Awards (SEFA) accurately reports Federal assistance. The Council’s fiscal year 2024 SEFA for the Promotion of the Humanities Federal/State Partnership program included expenditures from other fiscal years. Questioned Costs: Not applicable. Context: Total federal expenditures for the Promotion of the Humanities Federal/State Partnership program were $902,649 for the year ended October 31, 2024. Cause: The Council does not have adequate internal controls in place to ensure the accuracy of the SEFA. Effect: The Council is not reporting accurate financial information in its SEFA. Identification as a Repeat Finding: Prior Year Finding 2023-004 Recommendation: We recommend that the Council implement controls over financial reporting, including the SEFA, to ensure accuracy of financial data. Views of Responsible Officials: Management acknowledges the finding. See corrective action plan.
2024-001 - SEFA REPORTING Federal Program Information: Federal Agency and Program Name - National Endowment for the Humanities Promotion of the Humanities Federal/State Partnership Grant Number: SO-289836-23 Federal Assistance Listing Number 45.129 Criteria: 2 CFR 200.303 requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non- Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” 2 CFR 200.510(b) states that “the auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR 200.502.” Condition: The Council’s internal controls are not adequate to ensure the Schedule of Expenditures of Federal Awards (SEFA) accurately reports Federal assistance. The Council’s fiscal year 2024 SEFA for the Promotion of the Humanities Federal/State Partnership program included expenditures from other fiscal years. Questioned Costs: Not applicable. Context: Total federal expenditures for the Promotion of the Humanities Federal/State Partnership program were $902,649 for the year ended October 31, 2024. Cause: The Council does not have adequate internal controls in place to ensure the accuracy of the SEFA. Effect: The Council is not reporting accurate financial information in its SEFA. Identification as a Repeat Finding: Prior Year Finding 2023-004 Recommendation: We recommend that the Council implement controls over financial reporting, including the SEFA, to ensure accuracy of financial data. Views of Responsible Officials: Management acknowledges the finding. See corrective action plan.
Finding Number: 2024-001 Federal Program: Community Development Block Grant (CDBG) – Assistance Listing 14.218 Condition: The City’s original Schedule of Expenditures of Federal Awards (SEFA) and supporting audit documentation for the year ended October 31, 2024, did not include expenditures related to the Community Development Block Grant (CDBG) program. The omission was identified during the audit process and the SEFA was subsequently revised to include the CDBG program. Criteria: 2 CFR 200.510(b) requires the auditee to prepare a SEFA that lists individual federal programs by federal agency, including the Assistance Listing number, and to report total federal awards expended for each program. 2 CFR 200.508(b) requires the auditee to identify in its accounts all federal awards received and expended and the federal programs under which they were received. Cause: The omission occurred due to inadequate internal controls over the identification and reporting of all federal programs and related expenditures in the SEFA. Effect: As a result, the CDBG program was not initially subject to audit procedures required by the Uniform Guidance, increasing the risk that material noncompliance with federal requirements could go undetected. Recommendation: We recommend that the City strengthen its internal controls over the preparation of the SEFA to ensure that all federal programs and related expenditures are identified, recorded, and reported accurately and completely. This should include a review and reconciliation process involving all departments responsible for federal program administration. Management’s Response: Management concurs with the finding and has implemented additional review procedures to ensure all federal programs are identified and included in the SEFA in future years.
Finding 2024-002: Schedule of Expenditures of Federal Awards (Significant Deficiency) Information on the Federal Program: Assistance Listing Number 19.518 See Finding 2024-001. Finding 2024-002 is a significant deficiency in internal control over compliance in addition to non-compliance related to the Reporting compliance area. There were no questioned costs as a result of the corrections to the SEFA.Criteria or Specific Requirement: Management is responsible for the complete and fair presentation of the financial statements, including any supplementary information that is presented in relation to the financial statements, such as the Schedule of Expenditures of Federal Awards (SEFA). Also, in accordance with 2 CFR Section 200.510 (b)(2), WRC is required to include all direct and pass-through Federal awards expended during the fiscal year in the SEFA. Condition: After the start of the audit, we noted that two pass-through federal awards had been excluded from the SEFA. As a result, the SEFA was understated by $329,598 for the year ended September 30, 2024. Management provided a revised SEFA to correct these items after the major program had been determined and audit testing had already completed. The corrections to the SEFA did not change the major program determination and no questioned costs were noted. Cause: One of the pass-through federal awards was a new source of funding for WRC, which is why the expenditures were not originally included on the SEFA. The other pass-through federal award was not classified correctly as federal, which is why the expenditures were not originally included on the SEFA. Effect or Potential Effect: The SEFA provided at the start of the audit was understated by $329,598 and, as a result, it did not accurately report WRC’s federal expenditures. When the SEFA is not accurately prepared, this could have an effect on the determination of the major programs. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that WRC enhance its procedures related to the preparation of the SEFA to ensure that all required amounts are included, depending upon the terms of the grant award.
Title and Assistance Listing Number of Federal Program - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.510(b) requires organizations to prepare a schedule of expenditures of federal awards (SEFA), which includes total federal awards expended, as determined in accordance with 2 CFR 200.502. Condition - Expenditures incurred for the year ended September 30, 2024 were charged to various federal programs and were not reported on the SEFA for the year ended September 30, 2024. Context - The controls in place to ensure the completeness and accuracy of the SEFA were not operating as designed. As a result, $327,215 of expenditures of federal awards was not reported on the SEFA. These missing expenditures did not relate to major programs. Cause and Effect - The lack of a proper reconciliation of the SEFA to the financial records and lack of a review of the SEFA could result in an inaccurate SEFA and potentially impact major program determinations. Recommendation - We recommend the Board implement a process to ensure completion and timely review of a proper reconciliation of the SEFA to the financial statements prior to commencement of the audit. Views of Responsible Officials and Corrective Action Plan - Management will document a formal control to ensure proper reconciliation of the SEFA to the financial statements. The control will include the following: A report in substantially the same form as the annual SEFA will be developed at least quarterly and will include a reconciliation of grants receivable activity. Meetings will be held at least quarterly to review grant activity, including the aforementioned report, and assess impacts to the financial statements. These meetings will be conducted by treasury and accounting staff, and evidence of document review will be maintained. A centralized repository of information pertaining to federal grants activity will be maintained to ensure timely access to grant and expenditure data for relevant staff.
Title and Assistance Listing Number of Federal Program - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.510(b) requires organizations to prepare a schedule of expenditures of federal awards (SEFA), which includes total federal awards expended, as determined in accordance with 2 CFR 200.502. Condition - Expenditures incurred for the year ended September 30, 2024 were charged to various federal programs and were not reported on the SEFA for the year ended September 30, 2024. Context - The controls in place to ensure the completeness and accuracy of the SEFA were not operating as designed. As a result, $327,215 of expenditures of federal awards was not reported on the SEFA. These missing expenditures did not relate to major programs. Cause and Effect - The lack of a proper reconciliation of the SEFA to the financial records and lack of a review of the SEFA could result in an inaccurate SEFA and potentially impact major program determinations. Recommendation - We recommend the Board implement a process to ensure completion and timely review of a proper reconciliation of the SEFA to the financial statements prior to commencement of the audit. Views of Responsible Officials and Corrective Action Plan - Management will document a formal control to ensure proper reconciliation of the SEFA to the financial statements. The control will include the following: A report in substantially the same form as the annual SEFA will be developed at least quarterly and will include a reconciliation of grants receivable activity. Meetings will be held at least quarterly to review grant activity, including the aforementioned report, and assess impacts to the financial statements. These meetings will be conducted by treasury and accounting staff, and evidence of document review will be maintained. A centralized repository of information pertaining to federal grants activity will be maintained to ensure timely access to grant and expenditure data for relevant staff.
Title and Assistance Listing Number of Federal Program - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.510(b) requires organizations to prepare a schedule of expenditures of federal awards (SEFA), which includes total federal awards expended, as determined in accordance with 2 CFR 200.502. Condition - Expenditures incurred for the year ended September 30, 2024 were charged to various federal programs and were not reported on the SEFA for the year ended September 30, 2024. Context - The controls in place to ensure the completeness and accuracy of the SEFA were not operating as designed. As a result, $327,215 of expenditures of federal awards was not reported on the SEFA. These missing expenditures did not relate to major programs. Cause and Effect - The lack of a proper reconciliation of the SEFA to the financial records and lack of a review of the SEFA could result in an inaccurate SEFA and potentially impact major program determinations. Recommendation - We recommend the Board implement a process to ensure completion and timely review of a proper reconciliation of the SEFA to the financial statements prior to commencement of the audit. Views of Responsible Officials and Corrective Action Plan - Management will document a formal control to ensure proper reconciliation of the SEFA to the financial statements. The control will include the following: A report in substantially the same form as the annual SEFA will be developed at least quarterly and will include a reconciliation of grants receivable activity. Meetings will be held at least quarterly to review grant activity, including the aforementioned report, and assess impacts to the financial statements. These meetings will be conducted by treasury and accounting staff, and evidence of document review will be maintained. A centralized repository of information pertaining to federal grants activity will be maintained to ensure timely access to grant and expenditure data for relevant staff.