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.
Finding: 2024-003 CFDA Number: 14.218 Program Name: Community Development Block Grants Federal Agency: U.S. Department of Housing and Urban Development Type of Finding: Federal Award Finding Compliance Requirement: Reporting Questioned Costs: N/A Criteria According to 2 CFR 200.510(b), the auditee must prepare a SEFA that includes all federal awards expended, listed by federal program and Assistance Listings Number, along with the total amount provided to subrecipients. The SEFA must also include notes that describe the significant accounting policies used in preparing the schedule. The expenditures must be reported on the same basis of accounting as the auditee’s financial statements. Condition During our audit of the Friends of the Mission's SEFA for the fiscal year ended December 31, 2024, we noted that the SEFA did not accurately report the total federal awards expended for the U.S. Department of Housing and Urban Development, Assistance Listings Number 14.218. The SEFA understated expenditures by $409,477 from the Community Development Block Grants passed through from The City of Woodland. Cause The auditee’s internal controls over the preparation of the SEFA were not sufficient to ensure all federal expenditures were accurately identified and reported. Additionally, staff responsible for SEFA preparation were not fully trained on the requirements of 2 CFR 200.510(b). Effect: The inaccurate reporting of federal expenditures in the SEFA could lead to noncompliance with federal award requirements, misstatements in the single audit report, and potential delays or errors in the submission of the data collection form to the Federal Audit Clearinghouse. This may also impact the auditee’s ability to demonstrate compliance with federal regulations. Recommendations: We recommend that Friends of the Mission implement the following corrective actions: 1. Develop and document a formal process for preparing the SEFA, including procedures to identify and track all federal awards. 2. Provide training to staff responsible for SEFA preparation on the requirements of 2 CFR 200.510(b). 3. Implement a review process to ensure the SEFA is complete, accurate, and consistent with the auditee’s financial statements prior to submission. 4. Reconcile the SEFA with the general ledger and federal award records to ensure all expenditures are properly reported. Management's Response Management is aware of the finding and has taken steps to rectify the finding so that it does not repeat in future years.
Federal agency: U.S. Department of the Treasury Federal program title: Coronavirus Capital Projects Fund Assistance Listing (ALN): 21.029 Pass-through agency: State of Delaware Period of performance: Through December 31, 2026 Finding Number: 2024-001 Type of finding: - Significant Deficiency in Internal Control over Compliance, and - Noncompliance with 2 CFR §200.510(b) (SEFA completeness) Criteria or Specific Requirement: - SEFA content and completeness. Under 2 CFR §200.510(b), the auditee must prepare a complete Schedule of Expenditures of Federal Awards (SEFA) listing each federal program by federal agency and ALN, and for subawards, the pass-through entity’s name and identifying number. - Auditor reporting. Audit findings must be reported under 2 CFR §200.516(a) when there is material noncompliance and/or significant deficiencies/material weaknesses related to federal programs. Condition: During the audit, we noted that the Organization’s initial SEFA did not include all federal pass-through awards, including certain U.S. Department of the Treasury – Coronavirus Capital Projects Fund (ALN 21.029) subawards administered by the state of Delaware. The additional federal awards were identified by the auditors and subsequently added to the SEFA prior to report issuance. Questioned Costs: None were identified as part of this finding. Context: The omission was identified during SEFA procedures and major program determination. Because the SEFA is the basis for planning and selecting major programs, initial incompleteness could have affected major program determination and compliance testing. (SEFA must include ALN, pass-through, and award IDs per 2 CFR §200.510(b); audit findings are required to be reported per §200.516(a).) Cause: Controls over SEFA preparation and federal award identification were not sufficient to ensure all pass-through federal awards (including ARPA CPF) were captured with required identifiers (federal agency, ALN 21.029, pass-through name/number) before year-end reporting. Effect: An initially incomplete SEFA increases the risk that: - major programs are not properly identified for testing (§200.518) - the auditor may need to modify the SEFA in-relation-to opinion or compliance opinion if not corrected before report issuance (§200.515). - cause a delay in the audit Repeat Finding: No Recommendation: We recommend management implement (and document) SEFA preparation controls to ensure completeness and accuracy, including: 1. Maintaining a central grant repository containing award documents with federal agency, ALN (21.029), FAIN/prime award, pass-through entity, pass-through ID(s), period of performance, and award amounts. 2. Performing a year-end SEFA reconciliation from the general ledger and grant subledger to the repository, confirming all pass-through awards are captured with required ALN and identifiers per §200.510(b). 3. Obtaining written ALN/FAIN confirmations from pass-through entities for any awards lacking federal identifiers and retaining those confirmations in the grant file. Views of Responsible Officials: Christina Cultural Center experienced a SEFA completeness finding during a year with bookkeeping turnover, which affected the initial compilation of federal award activity. In response, management worked closely with the audit team to confirm the complete listing of awards, validate pass-through entity details, and support accurate SEFA presentation. The organization has also identified cross-training as a key next step to strengthen continuity and reduce key-person dependency going forward.
Finding No. 2024-001 Implement System-Based Tracking of Federal Expenditures Assistance Listing Number: 93.566 Program Name: Refugee and Entrant Assistance State/Replacement Designee Administered Programs Federal Agency: Department of Health and Human Services (HHS) Passed Through Entities: 1. California Department of Social Services 2. University of California, San Diego 3. California Rural Legal Assistance Foundation 4. San Diego Refugee Communities Coalition/United Women of East Africa Support Team 5. Public Health Institute (PHI) Federal Award Numbers: ALSP22-0002-A1, ALSP23-0001, PUR00533092, ACS22-05-CAIR, 06568-AR76924 Federal Award Year: August 1, 2022 to June 30, 2026 Compliance Requirement: Activities Allowed or Unallowed Criteria: Management is responsible for designing, implementing, and maintaining an internal control system that ensures accurate financial reporting. Effective internal control over financial reporting provides reasonable assurance regarding the completeness and accuracy of accounting records, and compliance with grantor requirements. 2 CFR 200.510 Financial Statements require auditees to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee's financial statements. This schedule must include the total Federal awards expended, as determined in accordance with 2 CFR 200.502. The information presented should be consistent with the accounting records (i.e., general ledger). In addition, Section 2 CFR 200.302(b)(1) provides that non-Federal entities must maintain effective control over and accountability for all funds, and must identify, in their accounts, all Federal awards received and expended. Condition: During our review of the SEFA, we noted that CAIR-CA utilizes workbooks outside of its accounting software to track federal expenditures. The workbooks do not reconcile directly with the general ledger (GL), so management performs a separate reconciliation to support the SEFA amounts. This approach was similarly observed in the prior year's audit. Cause: The prior year audit was completed in August 2025, after the close of the fiscal year 2024. As a result, management was still in the process of implementing a system-based tracking during the year 2024. CAIR-CA’s processes for tracking federal awards are continuing to develop, as this is only the second year under Single Audit. Effect: Using manual workbooks requires additional manual effort and may make reconciliation between SEFA and GL more time-consuming, and may result in inaccurate or incomplete reporting. Questioned Cost: None Recommendation: We recommend that CAIR-CA continue enhancing its accounting processes to track federal expenditures directly within its accounting software. This could include GL tracking codes or other similar identifiers for federal programs. System based tracking would simplify SEFA preparation, improve consistency with the general ledger, and strengthen monitoring of federal expenditures. Views of Responsible Officials and Corrective Action Plan: Management concurs with the finding and has already updated the accounting system to incorporate grant-specific tracking codes to further align with federal reporting standards. Because the organization’s first single audit in FY2023 was conducted concurrently with the FY2024 single audit, there was limited opportunity for these procedural improvements to be reflected in the FY2024 single audit testing cycle. As a result, the impact of these changes will be more fully reflected in the FY2025 single audit, which is scheduled to commence this year. As part of a layered approach to internal controls, excel worksheets will continue to be used as a supplementary monitoring tool, providing an additional cross-check to the system-generated reports. Responsible person: Jackie Ramirez, Operations & Finance Associate Director Implementation date: November 20, 2025
Information on Federal Programs: 93.083 – Centers for Disease Control and Prevention: Prevention of Disease, Disability, and Death through Immunization & Control of Respiratory & Related Diseases. Criteria or Specific Requirements: 2 CFR §200.510(b) requires recipients of Federal funds to prepare a SEFA for the period covered by the auditee’s financial statements that includes Federal awards expended during that fiscal year. 2 CFR §500.502 provides that the determination of when a Federal award is expended must be based on when the activity related to the Federal award occurs. Condition: During testing of the SEFA for the year ended December 31, 2024, we noted that certain Federal program expenditures related to activities incurred in fiscal year 2023 were reported in the 2024 SEFA instead of in the 2023 SEFA. Cause: Management’s procedures for preparing and reviewing the SEFA did not include sufficient controls to ensure that expenditures are reported in the correct fiscal year. Effect: The SEFA for the year ended December 31, 2023 was incomplete, and the SEFA for the year ended December 31, 2024 includes expenditures that related to activities incurred in fiscal year 2023. Although the expenditures were allowable costs of the Federal program, the timing misstatement affects the accuracy of SEFA presentation and could affect the usefulness of SEFA information to Federal agencies and pass-through entities in their monitoring and oversight. The error did not impact the major program selection process for 2023 or 2024.Perspective: This issue was identified during our testing of the SEFA for the year ended December 31, 2024, when we noted that ATS reported $114,984 of Federal award expenditures in 2024 that related to activities incurred in fiscal year 2023. These expenditures should have been reported in the SEFA for year ended December 31, 2023. Questioned Costs: None. Identification as a Repeat Finding: Not applicable. Recommendation: ATS should implement formal procedures for compiling the SEFA, including (1) reconciling SEFA amounts to the general ledger and other supporting records, (2) performing a year-end review to confirm that expenditures are reported in the correct fiscal year in accordance with 2 CFR §200.502 and 2 CFR §200.510(b), and (3) documenting supervisory review of the SEFA prior to finalization.
Reporting – Incomplete Schedule of Expenditures of Federal Awards Identification as a Repeat Finding: Not a repeat finding Federal Awards: 21.027 - Coronavirus State and Local Fiscal REcovery Funds Finding: The Authority did not properly identify proceeds received under a pass-through loan program as including federal award funds under the U.S. Department of Treasury Coronavirus State and Local Fiscal Recovery Funds program, and therefore the loan was improperly excluded from the schedule of expenditures of federal awards (SEFA). Sample Size and Population: Sampling was not applicable to this finding. Questioned Costs: None Criteria: The Authority is required to report all federal awards expended during the audit period on the SEFA. For federal loan programs, federal awards expended include the value of new loans received during the audit period, and the SEFA notes must identify outstanding loan balances at the end of the audit period. 2 CFR § 200.502(a)(3), 2 CFR § 200.502(b)(1), and 2 CFR § 200.510(b)(5). Condition: The Authority’s originally issued 2024 SEFA omitted $2,477,915 of federal expenditures related to a pass-through loan from the Washington State Department of Commerce. The loan included federal funds from the U.S. Department of the Treasury’s Coronavirus State and Local Fiscal Recovery Funds program, Assistance Listing 21.027. The entire federal portion of the loan was drawn during the year ended December 31, 2024, and the outstanding balance of the federal portion of the loan was $2,477,915 at December 31, 2024 and $0 at December 31, 2023. The omission was identified after the original 2024 Single Audit report had been issued Cause: The Authority did not have an effective process to ensure that all departments communicated federal award and loan information to the finance department for SEFA reporting. Effect: The originally issued SEFA was materially understated by $2,477,915, and the SEFA notes omitted the $2,477,915 outstanding federal loan balance at December 31, 2024. The omission affected the major program determination because Assistance Listing 21.027 was not included in the original SEFA or original major program selection. As a result, the originally issued Single Audit reporting package did not include the revised SEFA amounts, did not identify ALN 21.027 as a major program, and did not include auditor testing and reporting over the ALN 21.027 major program. Recommendations: Management should implement procedures to ensure all grant agreements, loan agreements, pass-through award notices, and related amendments are reviewed by the finance department to determine whether they include federal funds. Management should also require communication between project management and finance personnel, perform a year-end reconciliation of loan draws and outstanding balances to the SEFA, and document review of the SEFA and related notes before issuance. Management Response: Management response is reported in the “Corrective Action Plan” at the end of this report. Contact Person: Lowel Krueger, Executive Director
2024-001 - SEFA REPORTING Federal Program Information: Federal Agency and Program Name - National Endowment for the Humanities Promotion of the Humanities Federal/State Partnership Grant Number: SO-289836-23 Federal Assistance Listing Number 45.129 Criteria: 2 CFR 200.303 requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non- Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” 2 CFR 200.510(b) states that “the auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR 200.502.” Condition: The Council’s internal controls are not adequate to ensure the Schedule of Expenditures of Federal Awards (SEFA) accurately reports Federal assistance. The Council’s fiscal year 2024 SEFA for the Promotion of the Humanities Federal/State Partnership program included expenditures from other fiscal years. Questioned Costs: Not applicable. Context: Total federal expenditures for the Promotion of the Humanities Federal/State Partnership program were $902,649 for the year ended October 31, 2024. Cause: The Council does not have adequate internal controls in place to ensure the accuracy of the SEFA. Effect: The Council is not reporting accurate financial information in its SEFA. Identification as a Repeat Finding: Prior Year Finding 2023-004 Recommendation: We recommend that the Council implement controls over financial reporting, including the SEFA, to ensure accuracy of financial data. Views of Responsible Officials: Management acknowledges the finding. See corrective action plan.
2024-001 - SEFA REPORTING Federal Program Information: Federal Agency and Program Name - National Endowment for the Humanities Promotion of the Humanities Federal/State Partnership Grant Number: SO-289836-23 Federal Assistance Listing Number 45.129 Criteria: 2 CFR 200.303 requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non- Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” 2 CFR 200.510(b) states that “the auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR 200.502.” Condition: The Council’s internal controls are not adequate to ensure the Schedule of Expenditures of Federal Awards (SEFA) accurately reports Federal assistance. The Council’s fiscal year 2024 SEFA for the Promotion of the Humanities Federal/State Partnership program included expenditures from other fiscal years. Questioned Costs: Not applicable. Context: Total federal expenditures for the Promotion of the Humanities Federal/State Partnership program were $902,649 for the year ended October 31, 2024. Cause: The Council does not have adequate internal controls in place to ensure the accuracy of the SEFA. Effect: The Council is not reporting accurate financial information in its SEFA. Identification as a Repeat Finding: Prior Year Finding 2023-004 Recommendation: We recommend that the Council implement controls over financial reporting, including the SEFA, to ensure accuracy of financial data. Views of Responsible Officials: Management acknowledges the finding. See corrective action plan.
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.
Title and Assistance Listing Number of Federal Program - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.510(b) requires organizations to prepare a schedule of expenditures of federal awards (SEFA), which includes total federal awards expended, as determined in accordance with 2 CFR 200.502. Condition - Expenditures incurred for the year ended September 30, 2024 were charged to various federal programs and were not reported on the SEFA for the year ended September 30, 2024. Context - The controls in place to ensure the completeness and accuracy of the SEFA were not operating as designed. As a result, $327,215 of expenditures of federal awards was not reported on the SEFA. These missing expenditures did not relate to major programs. Cause and Effect - The lack of a proper reconciliation of the SEFA to the financial records and lack of a review of the SEFA could result in an inaccurate SEFA and potentially impact major program determinations. Recommendation - We recommend the Board implement a process to ensure completion and timely review of a proper reconciliation of the SEFA to the financial statements prior to commencement of the audit. Views of Responsible Officials and Corrective Action Plan - Management will document a formal control to ensure proper reconciliation of the SEFA to the financial statements. The control will include the following: A report in substantially the same form as the annual SEFA will be developed at least quarterly and will include a reconciliation of grants receivable activity. Meetings will be held at least quarterly to review grant activity, including the aforementioned report, and assess impacts to the financial statements. These meetings will be conducted by treasury and accounting staff, and evidence of document review will be maintained. A centralized repository of information pertaining to federal grants activity will be maintained to ensure timely access to grant and expenditure data for relevant staff.
Title and Assistance Listing Number of Federal Program - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.510(b) requires organizations to prepare a schedule of expenditures of federal awards (SEFA), which includes total federal awards expended, as determined in accordance with 2 CFR 200.502. Condition - Expenditures incurred for the year ended September 30, 2024 were charged to various federal programs and were not reported on the SEFA for the year ended September 30, 2024. Context - The controls in place to ensure the completeness and accuracy of the SEFA were not operating as designed. As a result, $327,215 of expenditures of federal awards was not reported on the SEFA. These missing expenditures did not relate to major programs. Cause and Effect - The lack of a proper reconciliation of the SEFA to the financial records and lack of a review of the SEFA could result in an inaccurate SEFA and potentially impact major program determinations. Recommendation - We recommend the Board implement a process to ensure completion and timely review of a proper reconciliation of the SEFA to the financial statements prior to commencement of the audit. Views of Responsible Officials and Corrective Action Plan - Management will document a formal control to ensure proper reconciliation of the SEFA to the financial statements. The control will include the following: A report in substantially the same form as the annual SEFA will be developed at least quarterly and will include a reconciliation of grants receivable activity. Meetings will be held at least quarterly to review grant activity, including the aforementioned report, and assess impacts to the financial statements. These meetings will be conducted by treasury and accounting staff, and evidence of document review will be maintained. A centralized repository of information pertaining to federal grants activity will be maintained to ensure timely access to grant and expenditure data for relevant staff.
Title and Assistance Listing Number of Federal Program - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.510(b) requires organizations to prepare a schedule of expenditures of federal awards (SEFA), which includes total federal awards expended, as determined in accordance with 2 CFR 200.502. Condition - Expenditures incurred for the year ended September 30, 2024 were charged to various federal programs and were not reported on the SEFA for the year ended September 30, 2024. Context - The controls in place to ensure the completeness and accuracy of the SEFA were not operating as designed. As a result, $327,215 of expenditures of federal awards was not reported on the SEFA. These missing expenditures did not relate to major programs. Cause and Effect - The lack of a proper reconciliation of the SEFA to the financial records and lack of a review of the SEFA could result in an inaccurate SEFA and potentially impact major program determinations. Recommendation - We recommend the Board implement a process to ensure completion and timely review of a proper reconciliation of the SEFA to the financial statements prior to commencement of the audit. Views of Responsible Officials and Corrective Action Plan - Management will document a formal control to ensure proper reconciliation of the SEFA to the financial statements. The control will include the following: A report in substantially the same form as the annual SEFA will be developed at least quarterly and will include a reconciliation of grants receivable activity. Meetings will be held at least quarterly to review grant activity, including the aforementioned report, and assess impacts to the financial statements. These meetings will be conducted by treasury and accounting staff, and evidence of document review will be maintained. A centralized repository of information pertaining to federal grants activity will be maintained to ensure timely access to grant and expenditure data for relevant staff.
Title and Assistance Listing Number of Federal Program - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.510(b) requires organizations to prepare a schedule of expenditures of federal awards (SEFA), which includes total federal awards expended, as determined in accordance with 2 CFR 200.502. Condition - Expenditures incurred for the year ended September 30, 2024 were charged to various federal programs and were not reported on the SEFA for the year ended September 30, 2024. Context - The controls in place to ensure the completeness and accuracy of the SEFA were not operating as designed. As a result, $327,215 of expenditures of federal awards was not reported on the SEFA. These missing expenditures did not relate to major programs. Cause and Effect - The lack of a proper reconciliation of the SEFA to the financial records and lack of a review of the SEFA could result in an inaccurate SEFA and potentially impact major program determinations. Recommendation - We recommend the Board implement a process to ensure completion and timely review of a proper reconciliation of the SEFA to the financial statements prior to commencement of the audit. Views of Responsible Officials and Corrective Action Plan - Management will document a formal control to ensure proper reconciliation of the SEFA to the financial statements. The control will include the following: A report in substantially the same form as the annual SEFA will be developed at least quarterly and will include a reconciliation of grants receivable activity. Meetings will be held at least quarterly to review grant activity, including the aforementioned report, and assess impacts to the financial statements. These meetings will be conducted by treasury and accounting staff, and evidence of document review will be maintained. A centralized repository of information pertaining to federal grants activity will be maintained to ensure timely access to grant and expenditure data for relevant staff.
Title and Assistance Listing Number of Federal Program - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.510(b) requires organizations to prepare a schedule of expenditures of federal awards (SEFA), which includes total federal awards expended, as determined in accordance with 2 CFR 200.502. Condition - Expenditures incurred for the year ended September 30, 2024 were charged to various federal programs and were not reported on the SEFA for the year ended September 30, 2024. Context - The controls in place to ensure the completeness and accuracy of the SEFA were not operating as designed. As a result, $327,215 of expenditures of federal awards was not reported on the SEFA. These missing expenditures did not relate to major programs. Cause and Effect - The lack of a proper reconciliation of the SEFA to the financial records and lack of a review of the SEFA could result in an inaccurate SEFA and potentially impact major program determinations. Recommendation - We recommend the Board implement a process to ensure completion and timely review of a proper reconciliation of the SEFA to the financial statements prior to commencement of the audit. Views of Responsible Officials and Corrective Action Plan - Management will document a formal control to ensure proper reconciliation of the SEFA to the financial statements. The control will include the following: A report in substantially the same form as the annual SEFA will be developed at least quarterly and will include a reconciliation of grants receivable activity. Meetings will be held at least quarterly to review grant activity, including the aforementioned report, and assess impacts to the financial statements. These meetings will be conducted by treasury and accounting staff, and evidence of document review will be maintained. A centralized repository of information pertaining to federal grants activity will be maintained to ensure timely access to grant and expenditure data for relevant staff.
Title and Assistance Listing Number of Federal Program - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.510(b) requires organizations to prepare a schedule of expenditures of federal awards (SEFA), which includes total federal awards expended, as determined in accordance with 2 CFR 200.502. Condition - Expenditures incurred for the year ended September 30, 2024 were charged to various federal programs and were not reported on the SEFA for the year ended September 30, 2024. Context - The controls in place to ensure the completeness and accuracy of the SEFA were not operating as designed. As a result, $327,215 of expenditures of federal awards was not reported on the SEFA. These missing expenditures did not relate to major programs. Cause and Effect - The lack of a proper reconciliation of the SEFA to the financial records and lack of a review of the SEFA could result in an inaccurate SEFA and potentially impact major program determinations. Recommendation - We recommend the Board implement a process to ensure completion and timely review of a proper reconciliation of the SEFA to the financial statements prior to commencement of the audit. Views of Responsible Officials and Corrective Action Plan - Management will document a formal control to ensure proper reconciliation of the SEFA to the financial statements. The control will include the following: A report in substantially the same form as the annual SEFA will be developed at least quarterly and will include a reconciliation of grants receivable activity. Meetings will be held at least quarterly to review grant activity, including the aforementioned report, and assess impacts to the financial statements. These meetings will be conducted by treasury and accounting staff, and evidence of document review will be maintained. A centralized repository of information pertaining to federal grants activity will be maintained to ensure timely access to grant and expenditure data for relevant staff.
Title and Assistance Listing Number of Federal Program - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.510(b) requires organizations to prepare a schedule of expenditures of federal awards (SEFA), which includes total federal awards expended, as determined in accordance with 2 CFR 200.502. Condition - Expenditures incurred for the year ended September 30, 2024 were charged to various federal programs and were not reported on the SEFA for the year ended September 30, 2024. Context - The controls in place to ensure the completeness and accuracy of the SEFA were not operating as designed. As a result, $327,215 of expenditures of federal awards was not reported on the SEFA. These missing expenditures did not relate to major programs. Cause and Effect - The lack of a proper reconciliation of the SEFA to the financial records and lack of a review of the SEFA could result in an inaccurate SEFA and potentially impact major program determinations. Recommendation - We recommend the Board implement a process to ensure completion and timely review of a proper reconciliation of the SEFA to the financial statements prior to commencement of the audit. Views of Responsible Officials and Corrective Action Plan - Management will document a formal control to ensure proper reconciliation of the SEFA to the financial statements. The control will include the following: A report in substantially the same form as the annual SEFA will be developed at least quarterly and will include a reconciliation of grants receivable activity. Meetings will be held at least quarterly to review grant activity, including the aforementioned report, and assess impacts to the financial statements. These meetings will be conducted by treasury and accounting staff, and evidence of document review will be maintained. A centralized repository of information pertaining to federal grants activity will be maintained to ensure timely access to grant and expenditure data for relevant staff.
Title and Assistance Listing Number of Federal Program - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.510(b) requires organizations to prepare a schedule of expenditures of federal awards (SEFA), which includes total federal awards expended, as determined in accordance with 2 CFR 200.502. Condition - Expenditures incurred for the year ended September 30, 2024 were charged to various federal programs and were not reported on the SEFA for the year ended September 30, 2024. Context - The controls in place to ensure the completeness and accuracy of the SEFA were not operating as designed. As a result, $327,215 of expenditures of federal awards was not reported on the SEFA. These missing expenditures did not relate to major programs. Cause and Effect - The lack of a proper reconciliation of the SEFA to the financial records and lack of a review of the SEFA could result in an inaccurate SEFA and potentially impact major program determinations. Recommendation - We recommend the Board implement a process to ensure completion and timely review of a proper reconciliation of the SEFA to the financial statements prior to commencement of the audit. Views of Responsible Officials and Corrective Action Plan - Management will document a formal control to ensure proper reconciliation of the SEFA to the financial statements. The control will include the following: A report in substantially the same form as the annual SEFA will be developed at least quarterly and will include a reconciliation of grants receivable activity. Meetings will be held at least quarterly to review grant activity, including the aforementioned report, and assess impacts to the financial statements. These meetings will be conducted by treasury and accounting staff, and evidence of document review will be maintained. A centralized repository of information pertaining to federal grants activity will be maintained to ensure timely access to grant and expenditure data for relevant staff.
Title and Assistance Listing Number of Federal Program - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.510(b) requires organizations to prepare a schedule of expenditures of federal awards (SEFA), which includes total federal awards expended, as determined in accordance with 2 CFR 200.502. Condition - Expenditures incurred for the year ended September 30, 2024 were charged to various federal programs and were not reported on the SEFA for the year ended September 30, 2024. Context - The controls in place to ensure the completeness and accuracy of the SEFA were not operating as designed. As a result, $327,215 of expenditures of federal awards was not reported on the SEFA. These missing expenditures did not relate to major programs. Cause and Effect - The lack of a proper reconciliation of the SEFA to the financial records and lack of a review of the SEFA could result in an inaccurate SEFA and potentially impact major program determinations. Recommendation - We recommend the Board implement a process to ensure completion and timely review of a proper reconciliation of the SEFA to the financial statements prior to commencement of the audit. Views of Responsible Officials and Corrective Action Plan - Management will document a formal control to ensure proper reconciliation of the SEFA to the financial statements. The control will include the following: A report in substantially the same form as the annual SEFA will be developed at least quarterly and will include a reconciliation of grants receivable activity. Meetings will be held at least quarterly to review grant activity, including the aforementioned report, and assess impacts to the financial statements. These meetings will be conducted by treasury and accounting staff, and evidence of document review will be maintained. A centralized repository of information pertaining to federal grants activity will be maintained to ensure timely access to grant and expenditure data for relevant staff.
Title and Assistance Listing Number of Federal Program - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.510(b) requires organizations to prepare a schedule of expenditures of federal awards (SEFA), which includes total federal awards expended, as determined in accordance with 2 CFR 200.502. Condition - Expenditures incurred for the year ended September 30, 2024 were charged to various federal programs and were not reported on the SEFA for the year ended September 30, 2024. Context - The controls in place to ensure the completeness and accuracy of the SEFA were not operating as designed. As a result, $327,215 of expenditures of federal awards was not reported on the SEFA. These missing expenditures did not relate to major programs. Cause and Effect - The lack of a proper reconciliation of the SEFA to the financial records and lack of a review of the SEFA could result in an inaccurate SEFA and potentially impact major program determinations. Recommendation - We recommend the Board implement a process to ensure completion and timely review of a proper reconciliation of the SEFA to the financial statements prior to commencement of the audit. Views of Responsible Officials and Corrective Action Plan - Management will document a formal control to ensure proper reconciliation of the SEFA to the financial statements. The control will include the following: A report in substantially the same form as the annual SEFA will be developed at least quarterly and will include a reconciliation of grants receivable activity. Meetings will be held at least quarterly to review grant activity, including the aforementioned report, and assess impacts to the financial statements. These meetings will be conducted by treasury and accounting staff, and evidence of document review will be maintained. A centralized repository of information pertaining to federal grants activity will be maintained to ensure timely access to grant and expenditure data for relevant staff.