Finding 2023-001 Material Weakness: Schedule of Expenditures of Federal Awards (SEFA) – Control Finding Criteria Or Specific Requirement: 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 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. Southwest Organizing Project (the Project) 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 SEFA was incomplete and contained inaccurate assistance listing numbers. Additionally, federal programs were excluded from the SEFA in error and federal expenditures included unallowable amounts. As a result, while not material to the financial statements, the SFEA required material adjustments during the audit process. Cause: Management does not have an internal control process in place to ensure an accurate SEFA. Effect: The possibility exists that errors within the SEFA could become material to the financial statements or result in an incorrect major program determination. Questioned Costs: Not applicable Context: A sufficient review of the SEFA did not occur so errors were not detected by management. Identification As A Repeat Finding: N/A Recommendation: The Project should strengthen its internal controls by implementing additional training and oversight of personnel to ensure the SEFA accurately reflects federal expenditures for the fiscal year. Views Of Responsible Officials And Planned Corrective Action: An adequate system of internal controls will be put in place by the end of fiscal year 2024. To ensure SEFA will include accurate assisting listing numbers and accurate inclusion of all federal programs. Allowable and unallowable costs will be reviewed to ensure accurate federal expenditure reporting. Management will perform an exhaustive review of all grants to close out the fiscal year in preparation for the audit process. In addition to these, SWOP will work with a consultant to provide necessary training of finance personnel.
Finding 2023-001 Material Weakness: Schedule of Expenditures of Federal Awards (SEFA) – Control Finding Criteria Or Specific Requirement: 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 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. Southwest Organizing Project (the Project) 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 SEFA was incomplete and contained inaccurate assistance listing numbers. Additionally, federal programs were excluded from the SEFA in error and federal expenditures included unallowable amounts. As a result, while not material to the financial statements, the SFEA required material adjustments during the audit process. Cause: Management does not have an internal control process in place to ensure an accurate SEFA. Effect: The possibility exists that errors within the SEFA could become material to the financial statements or result in an incorrect major program determination. Questioned Costs: Not applicable Context: A sufficient review of the SEFA did not occur so errors were not detected by management. Identification As A Repeat Finding: N/A Recommendation: The Project should strengthen its internal controls by implementing additional training and oversight of personnel to ensure the SEFA accurately reflects federal expenditures for the fiscal year. Views Of Responsible Officials And Planned Corrective Action: An adequate system of internal controls will be put in place by the end of fiscal year 2024. To ensure SEFA will include accurate assisting listing numbers and accurate inclusion of all federal programs. Allowable and unallowable costs will be reviewed to ensure accurate federal expenditure reporting. Management will perform an exhaustive review of all grants to close out the fiscal year in preparation for the audit process. In addition to these, SWOP will work with a consultant to provide necessary training of finance personnel.
Finding 2023-001 Material Weakness: Schedule of Expenditures of Federal Awards (SEFA) – Control Finding Criteria Or Specific Requirement: 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 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. Southwest Organizing Project (the Project) 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 SEFA was incomplete and contained inaccurate assistance listing numbers. Additionally, federal programs were excluded from the SEFA in error and federal expenditures included unallowable amounts. As a result, while not material to the financial statements, the SFEA required material adjustments during the audit process. Cause: Management does not have an internal control process in place to ensure an accurate SEFA. Effect: The possibility exists that errors within the SEFA could become material to the financial statements or result in an incorrect major program determination. Questioned Costs: Not applicable Context: A sufficient review of the SEFA did not occur so errors were not detected by management. Identification As A Repeat Finding: N/A Recommendation: The Project should strengthen its internal controls by implementing additional training and oversight of personnel to ensure the SEFA accurately reflects federal expenditures for the fiscal year. Views Of Responsible Officials And Planned Corrective Action: An adequate system of internal controls will be put in place by the end of fiscal year 2024. To ensure SEFA will include accurate assisting listing numbers and accurate inclusion of all federal programs. Allowable and unallowable costs will be reviewed to ensure accurate federal expenditure reporting. Management will perform an exhaustive review of all grants to close out the fiscal year in preparation for the audit process. In addition to these, SWOP will work with a consultant to provide necessary training of finance personnel.
Finding 2023-001 Material Weakness: Schedule of Expenditures of Federal Awards (SEFA) – Control Finding Criteria Or Specific Requirement: 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 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. Southwest Organizing Project (the Project) 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 SEFA was incomplete and contained inaccurate assistance listing numbers. Additionally, federal programs were excluded from the SEFA in error and federal expenditures included unallowable amounts. As a result, while not material to the financial statements, the SFEA required material adjustments during the audit process. Cause: Management does not have an internal control process in place to ensure an accurate SEFA. Effect: The possibility exists that errors within the SEFA could become material to the financial statements or result in an incorrect major program determination. Questioned Costs: Not applicable Context: A sufficient review of the SEFA did not occur so errors were not detected by management. Identification As A Repeat Finding: N/A Recommendation: The Project should strengthen its internal controls by implementing additional training and oversight of personnel to ensure the SEFA accurately reflects federal expenditures for the fiscal year. Views Of Responsible Officials And Planned Corrective Action: An adequate system of internal controls will be put in place by the end of fiscal year 2024. To ensure SEFA will include accurate assisting listing numbers and accurate inclusion of all federal programs. Allowable and unallowable costs will be reviewed to ensure accurate federal expenditure reporting. Management will perform an exhaustive review of all grants to close out the fiscal year in preparation for the audit process. In addition to these, SWOP will work with a consultant to provide necessary training of finance personnel.
Finding 2023-001 Material Weakness: Schedule of Expenditures of Federal Awards (SEFA) – Control Finding Criteria Or Specific Requirement: 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 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. Southwest Organizing Project (the Project) 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 SEFA was incomplete and contained inaccurate assistance listing numbers. Additionally, federal programs were excluded from the SEFA in error and federal expenditures included unallowable amounts. As a result, while not material to the financial statements, the SFEA required material adjustments during the audit process. Cause: Management does not have an internal control process in place to ensure an accurate SEFA. Effect: The possibility exists that errors within the SEFA could become material to the financial statements or result in an incorrect major program determination. Questioned Costs: Not applicable Context: A sufficient review of the SEFA did not occur so errors were not detected by management. Identification As A Repeat Finding: N/A Recommendation: The Project should strengthen its internal controls by implementing additional training and oversight of personnel to ensure the SEFA accurately reflects federal expenditures for the fiscal year. Views Of Responsible Officials And Planned Corrective Action: An adequate system of internal controls will be put in place by the end of fiscal year 2024. To ensure SEFA will include accurate assisting listing numbers and accurate inclusion of all federal programs. Allowable and unallowable costs will be reviewed to ensure accurate federal expenditure reporting. Management will perform an exhaustive review of all grants to close out the fiscal year in preparation for the audit process. In addition to these, SWOP will work with a consultant to provide necessary training of finance personnel.
Criteria: 2 CFR 200.510(b) requires the auditee to prepare a schedule of federal awards (SEFA) that must contain federal awards expended during the period. Condition: On the original SEFA provided for the audit, the total federal expenditures reflected on the SEFA were inaccurate with excess amounts for some programs and the programs 21.027 and 10.561 were omitted on the initial SEFA report. This resulted in a restatement of the SEFA. Cause: Due to staff turnover, staff was unfamiliar with the specifics of the grant. Effect: SEFA was inaccurate. Recommendation: We recommend that management put controls in place over the preparation and review of the schedule of expenditures of federal awards to ensure that only (and all) federal expenditures are included. Management's Response: We agree with this finding. See corrective action plan.
Criteria: 2 CFR 200.510(b) requires the auditee to prepare a schedule of federal awards (SEFA) that must contain federal awards expended during the period. Condition: On the original SEFA provided for the audit, the total federal expenditures reflected on the SEFA were inaccurate with excess amounts for some programs and the programs 21.027 and 10.561 were omitted on the initial SEFA report. This resulted in a restatement of the SEFA. Cause: Due to staff turnover, staff was unfamiliar with the specifics of the grant. Effect: SEFA was inaccurate. Recommendation: We recommend that management put controls in place over the preparation and review of the schedule of expenditures of federal awards to ensure that only (and all) federal expenditures are included. Management's Response: We agree with this finding. See corrective action plan.
Criteria: 2 CFR 200.510(b) requires the auditee to prepare a schedule of federal awards (SEFA) that must contain federal awards expended during the period. Condition: On the original SEFA provided for the audit, the total federal expenditures reflected on the SEFA were inaccurate with excess amounts for some programs and the programs 21.027 and 10.561 were omitted on the initial SEFA report. This resulted in a restatement of the SEFA. Cause: Due to staff turnover, staff was unfamiliar with the specifics of the grant. Effect: SEFA was inaccurate. Recommendation: We recommend that management put controls in place over the preparation and review of the schedule of expenditures of federal awards to ensure that only (and all) federal expenditures are included. Management's Response: We agree with this finding. See corrective action plan.
Criteria: In accordance with the Uniform Guidance, 2 CFR 200.510(b), the auditee must prepare the schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements. Condition: The auditee did not finalize the schedule of expenditures of federal awards prior to signing the engagement letter and the start of the audit procedures for the fiscal year July 1, 2022 to June 30, 2023. Additionally, the prepared SEFA included totals representing contractor payments to Florence Crittenton (FCFS), which overstated SEFA total expenditures by $173,389. Context: Initially, the auditee stated that a single audit was not needed for fiscal year 2022-23, and that expenditures of federal awards was below $750,000. The audit engagement letter was prepared and signed, which excluded single audit language. During the course of the audit procedures, the SEFA was prepared by the auditee with the assistance of the auditor, and it was determined that the auditee incurred $816,420 in expenditures of federal awards in fiscal year covering July 1, 2022 to June 30, 2023. Upon the discovery that a single audit was needed for the testing period, the engagement letter was revised, and single audit procedures were completed. During the course of audit procedures for the Single Audit, it was discovered that the state of Montana considered Florence Crittenton to be a non-subrecipient for the stabilization grants under the Child Care and Development Block Grant. Effect: Non-compliance with the Uniform Guidance regarding SEFA preparation. Questioned Costs: There were no questioned costs identified. Cause: Florence Crittenton was not aware that federal expenditures for the fiscal year July 1, 2022 to June 30, 2023 were over $750,000 until the auditor requested documentation that federal expenditures were under $750,000. Recommendation: We recommend the organization review all contracts before the end of the fiscal year to ensure all funds received have the appropriate contracts from state and federal awarding entities, and that the organization begin SEFA preparation immediately following the end of the fiscal year to ensure it includes all federal funds expended and is completed prior to the start of audit procedures. Organization Response: Based on the way that the State of Montana has historically written their grant contracts, it has been difficult to decipher if the organization is a subrecipient or a contractor of the state. This was especially true for any contracts funded through Covid-19 CARES and ARPA funds. Additionally, FCFS was unclear if seed funds from the Innovation grant were considered expended or not. This confusion led to a mistake on the initial SEFA worksheet that indicated federal funds fell below $750,000. Upon further examination by all parties, it was determined that FCFS had in fact expended over $750,000 in federal funds. FCFS immediately signed an engagement letter for Douglas Wilson to complete the SEFA and has since complied with all testing requirements. To ensure this mistake does not happen again, FCFS designed a corrective action plan that will include confirming subrecipient or contractor status with all contracting agencies. This has already been completed with current contracts for FY24. FCFS has subsequently established additional measures to ensure complete review of all contracts and quarterly reporting of all grant spending, regardless of if it is a federal, state, or private grant.
Criteria: In accordance with the Uniform Guidance, 2 CFR 200.510(b), the auditee must prepare the schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements. Condition: The auditee did not finalize the schedule of expenditures of federal awards prior to signing the engagement letter and the start of the audit procedures for the fiscal year July 1, 2022 to June 30, 2023. Additionally, the prepared SEFA included totals representing contractor payments to Florence Crittenton (FCFS), which overstated SEFA total expenditures by $173,389. Context: Initially, the auditee stated that a single audit was not needed for fiscal year 2022-23, and that expenditures of federal awards was below $750,000. The audit engagement letter was prepared and signed, which excluded single audit language. During the course of the audit procedures, the SEFA was prepared by the auditee with the assistance of the auditor, and it was determined that the auditee incurred $816,420 in expenditures of federal awards in fiscal year covering July 1, 2022 to June 30, 2023. Upon the discovery that a single audit was needed for the testing period, the engagement letter was revised, and single audit procedures were completed. During the course of audit procedures for the Single Audit, it was discovered that the state of Montana considered Florence Crittenton to be a non-subrecipient for the stabilization grants under the Child Care and Development Block Grant. Effect: Non-compliance with the Uniform Guidance regarding SEFA preparation. Questioned Costs: There were no questioned costs identified. Cause: Florence Crittenton was not aware that federal expenditures for the fiscal year July 1, 2022 to June 30, 2023 were over $750,000 until the auditor requested documentation that federal expenditures were under $750,000. Recommendation: We recommend the organization review all contracts before the end of the fiscal year to ensure all funds received have the appropriate contracts from state and federal awarding entities, and that the organization begin SEFA preparation immediately following the end of the fiscal year to ensure it includes all federal funds expended and is completed prior to the start of audit procedures. Organization Response: Based on the way that the State of Montana has historically written their grant contracts, it has been difficult to decipher if the organization is a subrecipient or a contractor of the state. This was especially true for any contracts funded through Covid-19 CARES and ARPA funds. Additionally, FCFS was unclear if seed funds from the Innovation grant were considered expended or not. This confusion led to a mistake on the initial SEFA worksheet that indicated federal funds fell below $750,000. Upon further examination by all parties, it was determined that FCFS had in fact expended over $750,000 in federal funds. FCFS immediately signed an engagement letter for Douglas Wilson to complete the SEFA and has since complied with all testing requirements. To ensure this mistake does not happen again, FCFS designed a corrective action plan that will include confirming subrecipient or contractor status with all contracting agencies. This has already been completed with current contracts for FY24. FCFS has subsequently established additional measures to ensure complete review of all contracts and quarterly reporting of all grant spending, regardless of if it is a federal, state, or private grant.
PREPARATION OF SCHEDULE OF EXPENDITURES AND FEDERAL AWARDS QUESTIONED COSTS: N/A Criteria: The Uniform Guidance Subpart F section 200.510 requires the preparation of the Schedule of Expenditures of Federal Awards (SEFA) that includes an accurate reporting of federal awards expended based on the terms and conditions of the grants along with the amount of funds disbursed to sub-recipients. In order for the SEFA to be prepared accurately and properly report the amounts expended for federal awards, a system of controls should be in existence that includes the identification of federal expenditures, timely and accurate preparation and review of the amounts reported on the SEFA. Condition: The initial SEFA prepared by the School Board’s did not accurately include or identify all the federal award expenditures. This finding is repeated from the prior year. See the Summary Schedule of Prior Year Findings and Questioned Cost item 2022-003. Universe/ Population: None Sample size: None Cause: The grant awards or agreements were not properly interpreted or reviewed to identify or determine the proper amount to be reported as expenditures or SEFA. The 2 CFR Part 200, Appendix XI, Compliance Supplement publishes and distributed by the President of the United States’ Office of Management and Budget includes requirements for SEFA reporting that were not complied with. Effect: The SEFA provided to us for audit did not contain all the federal programs or the correct amounts of federal expenditures based on the terms of the grant awards and requirements to reporting on some of the federal programs reported. Inaccuracies or excluding information on the SEFA causes delays in completing the single audit and risks filing a SEFA that is incomplete or inaccurate. In addition, auditors may not identify and test the correct major federal programs in accordance with the Uniform Guidance. Recommendation: The School Board should strengthen its controls including its review and approval processes over the identification of federal programs, and the information and balances that are accumulated and reported on the SEFA to make sure the expenditures reported are an accurate representation of federal expenditures. View of Responsible Official: Management agrees with finding. Disaster Grants through FEMA are managed by rules and processes that are not easily accounted for in traditional accounting systems. Procedures will be strengthened to fully and accurately identify all federal program expenditures and record in the appropriate accounting funds.
Finding 2023-004: Inadequate Review of the Schedule of Expenditures of Federal Awards U.S. Department of Health and Human Services Federal Programs: Advanced Nursing Education Workforce Grant Program (ALN number 93.247) (Federal Award Year 2023), Family Planning Services (ALN number 93.217) (Federal Award Year 2023), and Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (ALN number 93.323) (Federal Award Year 2023) Repeat Finding: No Criteria: In accordance with 2 CFR 200.510, the auditee must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR 200.502. Condition: During our testing, we identified errors in the Organization’s SEFA for the year ended June 30, 2023. The errors were as follows: • Total federal expenditures for Assistance Listing Number (ALN) 93.247, Advanced Nursing Education Workforce Grant Program, were understated by $516,141. • Total federal expenditures for ALN 93.217, Family Planning Services, were overstated by $125,252. • The federal grantor for amounts passed through the Illinois Department of Public Health for ALN 93.323, Epidemiology and Laboratory Capacity for Infectious Disease (ELC), was incorrectly reported as the U.S. Department of the Treasury and should have been reported as the U.S. Department of Health and Human Services. Cause: The Organization did not have adequate internal controls in place over the review of the SEFA to ensure the SEFA was complete and accurate. . Effect: The errors contained in the SEFA led to inaccurate major program determination. After correcting the errors, an additional major program was identified. The data collection form and reporting package were not received by the Federal Audit Clearinghouse by the prescribed due date. Recommendation: We recommend the Organization enhance its internal controls over the review of the completeness and accuracy of the SEFA. View of responsible officials of the auditee: Management agrees with the finding and recommendation.
Finding 2023-004: Inadequate Review of the Schedule of Expenditures of Federal Awards U.S. Department of Health and Human Services Federal Programs: Advanced Nursing Education Workforce Grant Program (ALN number 93.247) (Federal Award Year 2023), Family Planning Services (ALN number 93.217) (Federal Award Year 2023), and Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (ALN number 93.323) (Federal Award Year 2023) Repeat Finding: No Criteria: In accordance with 2 CFR 200.510, the auditee must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR 200.502. Condition: During our testing, we identified errors in the Organization’s SEFA for the year ended June 30, 2023. The errors were as follows: • Total federal expenditures for Assistance Listing Number (ALN) 93.247, Advanced Nursing Education Workforce Grant Program, were understated by $516,141. • Total federal expenditures for ALN 93.217, Family Planning Services, were overstated by $125,252. • The federal grantor for amounts passed through the Illinois Department of Public Health for ALN 93.323, Epidemiology and Laboratory Capacity for Infectious Disease (ELC), was incorrectly reported as the U.S. Department of the Treasury and should have been reported as the U.S. Department of Health and Human Services. Cause: The Organization did not have adequate internal controls in place over the review of the SEFA to ensure the SEFA was complete and accurate. . Effect: The errors contained in the SEFA led to inaccurate major program determination. After correcting the errors, an additional major program was identified. The data collection form and reporting package were not received by the Federal Audit Clearinghouse by the prescribed due date. Recommendation: We recommend the Organization enhance its internal controls over the review of the completeness and accuracy of the SEFA. View of responsible officials of the auditee: Management agrees with the finding and recommendation.
Finding 2023-004: Inadequate Review of the Schedule of Expenditures of Federal Awards U.S. Department of Health and Human Services Federal Programs: Advanced Nursing Education Workforce Grant Program (ALN number 93.247) (Federal Award Year 2023), Family Planning Services (ALN number 93.217) (Federal Award Year 2023), and Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (ALN number 93.323) (Federal Award Year 2023) Repeat Finding: No Criteria: In accordance with 2 CFR 200.510, the auditee must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR 200.502. Condition: During our testing, we identified errors in the Organization’s SEFA for the year ended June 30, 2023. The errors were as follows: • Total federal expenditures for Assistance Listing Number (ALN) 93.247, Advanced Nursing Education Workforce Grant Program, were understated by $516,141. • Total federal expenditures for ALN 93.217, Family Planning Services, were overstated by $125,252. • The federal grantor for amounts passed through the Illinois Department of Public Health for ALN 93.323, Epidemiology and Laboratory Capacity for Infectious Disease (ELC), was incorrectly reported as the U.S. Department of the Treasury and should have been reported as the U.S. Department of Health and Human Services. Cause: The Organization did not have adequate internal controls in place over the review of the SEFA to ensure the SEFA was complete and accurate. . Effect: The errors contained in the SEFA led to inaccurate major program determination. After correcting the errors, an additional major program was identified. The data collection form and reporting package were not received by the Federal Audit Clearinghouse by the prescribed due date. Recommendation: We recommend the Organization enhance its internal controls over the review of the completeness and accuracy of the SEFA. View of responsible officials of the auditee: Management agrees with the finding and recommendation.
Finding 2023-002: Timely Submission of the Single Audit Reporting Package U.S. Department of Health and Human Services Federal Programs: Health Center Program Cluster (ALN numbers 93.224/93.527) (Federal Award Year 2023) and Advanced Nursing Education Workforce Grant Program (ALN number 93.247) (Federal Award Year 2023) Repeat Finding: No Criteria: In accordance with 2 CFR 200.512, the audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor’s report, or nine months after the end of the audit period. Additionally, as part of the data collection, a senior level representative of the auditee must attest that, among other things, the information included in its entirety is accurate and complete. In accordance with 2 CFR 200.510, the auditee must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR 200.502. Condition: The data collection form and reporting package were not submitted within nine months after the end of the audit period of June 30, 2023. Cause: The Organization did not have adequate internal controls in place over the review of the SEFA to ensure the SEFA was complete and accurate. The errors contained in the SEFA led to inaccurate major program determination, which ultimately led to the Organization not submitting the single audit reporting package by the prescribed due date. Effect: The data collection form and reporting package were not received by the Federal Audit Clearinghouse by the prescribed due date. Recommendation: We recommend the Organization enhance its internal controls over the review of the completeness and accuracy of the SEFA. We also recommend that management ensure that the data collection form and reporting package are submitted by the prescribed due date. View of responsible officials of the auditee: Management agrees with the finding and recommendation.
Finding 2023-002: Timely Submission of the Single Audit Reporting Package U.S. Department of Health and Human Services Federal Programs: Health Center Program Cluster (ALN numbers 93.224/93.527) (Federal Award Year 2023) and Advanced Nursing Education Workforce Grant Program (ALN number 93.247) (Federal Award Year 2023) Repeat Finding: No Criteria: In accordance with 2 CFR 200.512, the audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor’s report, or nine months after the end of the audit period. Additionally, as part of the data collection, a senior level representative of the auditee must attest that, among other things, the information included in its entirety is accurate and complete. In accordance with 2 CFR 200.510, the auditee must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR 200.502. Condition: The data collection form and reporting package were not submitted within nine months after the end of the audit period of June 30, 2023. Cause: The Organization did not have adequate internal controls in place over the review of the SEFA to ensure the SEFA was complete and accurate. The errors contained in the SEFA led to inaccurate major program determination, which ultimately led to the Organization not submitting the single audit reporting package by the prescribed due date. Effect: The data collection form and reporting package were not received by the Federal Audit Clearinghouse by the prescribed due date. Recommendation: We recommend the Organization enhance its internal controls over the review of the completeness and accuracy of the SEFA. We also recommend that management ensure that the data collection form and reporting package are submitted by the prescribed due date. View of responsible officials of the auditee: Management agrees with the finding and recommendation.
Finding 2023-002: Timely Submission of the Single Audit Reporting Package U.S. Department of Health and Human Services Federal Programs: Health Center Program Cluster (ALN numbers 93.224/93.527) (Federal Award Year 2023) and Advanced Nursing Education Workforce Grant Program (ALN number 93.247) (Federal Award Year 2023) Repeat Finding: No Criteria: In accordance with 2 CFR 200.512, the audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor’s report, or nine months after the end of the audit period. Additionally, as part of the data collection, a senior level representative of the auditee must attest that, among other things, the information included in its entirety is accurate and complete. In accordance with 2 CFR 200.510, the auditee must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR 200.502. Condition: The data collection form and reporting package were not submitted within nine months after the end of the audit period of June 30, 2023. Cause: The Organization did not have adequate internal controls in place over the review of the SEFA to ensure the SEFA was complete and accurate. The errors contained in the SEFA led to inaccurate major program determination, which ultimately led to the Organization not submitting the single audit reporting package by the prescribed due date. Effect: The data collection form and reporting package were not received by the Federal Audit Clearinghouse by the prescribed due date. Recommendation: We recommend the Organization enhance its internal controls over the review of the completeness and accuracy of the SEFA. We also recommend that management ensure that the data collection form and reporting package are submitted by the prescribed due date. View of responsible officials of the auditee: Management agrees with the finding and recommendation.
Finding 2023-002: Timely Submission of the Single Audit Reporting Package U.S. Department of Health and Human Services Federal Programs: Health Center Program Cluster (ALN numbers 93.224/93.527) (Federal Award Year 2023) and Advanced Nursing Education Workforce Grant Program (ALN number 93.247) (Federal Award Year 2023) Repeat Finding: No Criteria: In accordance with 2 CFR 200.512, the audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor’s report, or nine months after the end of the audit period. Additionally, as part of the data collection, a senior level representative of the auditee must attest that, among other things, the information included in its entirety is accurate and complete. In accordance with 2 CFR 200.510, the auditee must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR 200.502. Condition: The data collection form and reporting package were not submitted within nine months after the end of the audit period of June 30, 2023. Cause: The Organization did not have adequate internal controls in place over the review of the SEFA to ensure the SEFA was complete and accurate. The errors contained in the SEFA led to inaccurate major program determination, which ultimately led to the Organization not submitting the single audit reporting package by the prescribed due date. Effect: The data collection form and reporting package were not received by the Federal Audit Clearinghouse by the prescribed due date. Recommendation: We recommend the Organization enhance its internal controls over the review of the completeness and accuracy of the SEFA. We also recommend that management ensure that the data collection form and reporting package are submitted by the prescribed due date. View of responsible officials of the auditee: Management agrees with the finding and recommendation.
Finding 2023-002: Timely Submission of the Single Audit Reporting Package U.S. Department of Health and Human Services Federal Programs: Health Center Program Cluster (ALN numbers 93.224/93.527) (Federal Award Year 2023) and Advanced Nursing Education Workforce Grant Program (ALN number 93.247) (Federal Award Year 2023) Repeat Finding: No Criteria: In accordance with 2 CFR 200.512, the audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor’s report, or nine months after the end of the audit period. Additionally, as part of the data collection, a senior level representative of the auditee must attest that, among other things, the information included in its entirety is accurate and complete. In accordance with 2 CFR 200.510, the auditee must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR 200.502. Condition: The data collection form and reporting package were not submitted within nine months after the end of the audit period of June 30, 2023. Cause: The Organization did not have adequate internal controls in place over the review of the SEFA to ensure the SEFA was complete and accurate. The errors contained in the SEFA led to inaccurate major program determination, which ultimately led to the Organization not submitting the single audit reporting package by the prescribed due date. Effect: The data collection form and reporting package were not received by the Federal Audit Clearinghouse by the prescribed due date. Recommendation: We recommend the Organization enhance its internal controls over the review of the completeness and accuracy of the SEFA. We also recommend that management ensure that the data collection form and reporting package are submitted by the prescribed due date. View of responsible officials of the auditee: Management agrees with the finding and recommendation.
Criteria:2 CFR 200.510(b) requires the auditee to prepare a schedule of federal awards (SEFA) that must contain federal awards expended during the period. Condition: On the original SEFA provided for the audit, the total federal expenditures reflected on the SEFA were inaccurate amounts for some programs and the program 21.027 was omitted on the initial SEFA report. This resulted in a restatement of the SEFA. Cause: Due to staff turnover, staff was unfamiliar with the specifics of the grant. Effect:SEFA was inaccurate Recommendation:We recommend that management put controls in place over the preparation and review of the schedule of expenditures of federal awards to ensure that only (and all) federal expenditures are included. Management's Response: We agree with this finding. See corrective action plan.
Criteria:2 CFR 200.510(b) requires the auditee to prepare a schedule of federal awards (SEFA) that must contain federal awards expended during the period. Condition: On the original SEFA provided for the audit, the total federal expenditures reflected on the SEFA were inaccurate amounts for some programs and the program 21.027 was omitted on the initial SEFA report. This resulted in a restatement of the SEFA. Cause: Due to staff turnover, staff was unfamiliar with the specifics of the grant. Effect:SEFA was inaccurate Recommendation:We recommend that management put controls in place over the preparation and review of the schedule of expenditures of federal awards to ensure that only (and all) federal expenditures are included. Management's Response: We agree with this finding. See corrective action plan.
Criteria:2 CFR 200.510(b) requires the auditee to prepare a schedule of federal awards (SEFA) that must contain federal awards expended during the period. Condition: On the original SEFA provided for the audit, the total federal expenditures reflected on the SEFA were inaccurate amounts for some programs and the program 21.027 was omitted on the initial SEFA report. This resulted in a restatement of the SEFA. Cause: Due to staff turnover, staff was unfamiliar with the specifics of the grant. Effect:SEFA was inaccurate Recommendation:We recommend that management put controls in place over the preparation and review of the schedule of expenditures of federal awards to ensure that only (and all) federal expenditures are included. Management's Response: We agree with this finding. See corrective action plan.
2023-005 - Internal Control Over Compliance and Compliance – Reporting (Preparation of the Schedule of Expenditures of Federal Awards) Program- U.S. Department of Energy, National Forum for State and Territorial Chief Executives - HHS OA, Yr 10 and Yr 11, National Forum ALN: 93.528, Award #: 2U98OA09028, Award Year: 09/01/2022 – 09/29/2023 Program- U.S. Department of Health and Human Services, Strengthening Public Health Systems and Services through National Partnerships to Improve and Protect the Nation’s Health ALN: 93.421, Award #: Various, Award Year: 08/01/2018 – 07/31/2023 Criteria – 2 CFR Section §200.510(b) states in part: “The auditee must also prepare a schedule of expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with CFR Section §200.502 Basis for determining Federal awards expended.” The schedule must provide total Federal awards expended for each individual Federal program. In accordance with §200.302 Financial Management, a non-federal entity’s financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: (1) Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. (2) Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. (3) Records that identify adequately the source and application of funds for federally-funded activities. (4) Effective control over, and accountability for, all funds, property, and other assets. Condition – The internal controls established for the review and approval of the SEFA to ensure its completeness and accuracy did not operate as designed. During our testing of management’s preparation of the SEFA, it was determined that some federal award expenditures were excluded from the original SEFA provided by management. Management subsequently corrected the SEFA to reflect the inclusion of the federal expenditures. In addition, several versions were received from management prior to the final SEFA. Questioned Costs – None. Context – This is a condition identified per review of NGA Center’s compliance with specified requirements. Cause – NGA Center only prepares the SEFA once a year in conjunction with the annual audit. This annual process lends itself to less familiarity with the processes necessary to provide a complete SEFA reporting package and turnover in key personnel historically involved in the SEFA process negatively impacted the process. Effect – Failure to present the SEFA correctly can result in incorrect major program selection and incorrect reporting to federal agencies. The finding identified was not of a magnitude to impact BDO’s selection of major programs. Repeat Finding – This is not a repeat finding. Recommendation - We recommend management continue to focus on training for both preparer and reviewer of the SEFA to ensure the documented policies and procedures can be performed as prescribed to comply with Section §200.510(b). This will ensure that the SEFA provides all relevant information as prescribed. Views of Responsible Officials – NGA Center agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
2023-005 - Internal Control Over Compliance and Compliance – Reporting (Preparation of the Schedule of Expenditures of Federal Awards) Program- U.S. Department of Energy, National Forum for State and Territorial Chief Executives - HHS OA, Yr 10 and Yr 11, National Forum ALN: 93.528, Award #: 2U98OA09028, Award Year: 09/01/2022 – 09/29/2023 Program- U.S. Department of Health and Human Services, Strengthening Public Health Systems and Services through National Partnerships to Improve and Protect the Nation’s Health ALN: 93.421, Award #: Various, Award Year: 08/01/2018 – 07/31/2023 Criteria – 2 CFR Section §200.510(b) states in part: “The auditee must also prepare a schedule of expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with CFR Section §200.502 Basis for determining Federal awards expended.” The schedule must provide total Federal awards expended for each individual Federal program. In accordance with §200.302 Financial Management, a non-federal entity’s financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: (1) Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. (2) Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. (3) Records that identify adequately the source and application of funds for federally-funded activities. (4) Effective control over, and accountability for, all funds, property, and other assets. Condition – The internal controls established for the review and approval of the SEFA to ensure its completeness and accuracy did not operate as designed. During our testing of management’s preparation of the SEFA, it was determined that some federal award expenditures were excluded from the original SEFA provided by management. Management subsequently corrected the SEFA to reflect the inclusion of the federal expenditures. In addition, several versions were received from management prior to the final SEFA. Questioned Costs – None. Context – This is a condition identified per review of NGA Center’s compliance with specified requirements. Cause – NGA Center only prepares the SEFA once a year in conjunction with the annual audit. This annual process lends itself to less familiarity with the processes necessary to provide a complete SEFA reporting package and turnover in key personnel historically involved in the SEFA process negatively impacted the process. Effect – Failure to present the SEFA correctly can result in incorrect major program selection and incorrect reporting to federal agencies. The finding identified was not of a magnitude to impact BDO’s selection of major programs. Repeat Finding – This is not a repeat finding. Recommendation - We recommend management continue to focus on training for both preparer and reviewer of the SEFA to ensure the documented policies and procedures can be performed as prescribed to comply with Section §200.510(b). This will ensure that the SEFA provides all relevant information as prescribed. Views of Responsible Officials – NGA Center agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
2023-005 - Internal Control Over Compliance and Compliance – Reporting (Preparation of the Schedule of Expenditures of Federal Awards) Program- U.S. Department of Energy, National Forum for State and Territorial Chief Executives - HHS OA, Yr 10 and Yr 11, National Forum ALN: 93.528, Award #: 2U98OA09028, Award Year: 09/01/2022 – 09/29/2023 Program- U.S. Department of Health and Human Services, Strengthening Public Health Systems and Services through National Partnerships to Improve and Protect the Nation’s Health ALN: 93.421, Award #: Various, Award Year: 08/01/2018 – 07/31/2023 Criteria – 2 CFR Section §200.510(b) states in part: “The auditee must also prepare a schedule of expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with CFR Section §200.502 Basis for determining Federal awards expended.” The schedule must provide total Federal awards expended for each individual Federal program. In accordance with §200.302 Financial Management, a non-federal entity’s financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: (1) Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. (2) Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. (3) Records that identify adequately the source and application of funds for federally-funded activities. (4) Effective control over, and accountability for, all funds, property, and other assets. Condition – The internal controls established for the review and approval of the SEFA to ensure its completeness and accuracy did not operate as designed. During our testing of management’s preparation of the SEFA, it was determined that some federal award expenditures were excluded from the original SEFA provided by management. Management subsequently corrected the SEFA to reflect the inclusion of the federal expenditures. In addition, several versions were received from management prior to the final SEFA. Questioned Costs – None. Context – This is a condition identified per review of NGA Center’s compliance with specified requirements. Cause – NGA Center only prepares the SEFA once a year in conjunction with the annual audit. This annual process lends itself to less familiarity with the processes necessary to provide a complete SEFA reporting package and turnover in key personnel historically involved in the SEFA process negatively impacted the process. Effect – Failure to present the SEFA correctly can result in incorrect major program selection and incorrect reporting to federal agencies. The finding identified was not of a magnitude to impact BDO’s selection of major programs. Repeat Finding – This is not a repeat finding. Recommendation - We recommend management continue to focus on training for both preparer and reviewer of the SEFA to ensure the documented policies and procedures can be performed as prescribed to comply with Section §200.510(b). This will ensure that the SEFA provides all relevant information as prescribed. Views of Responsible Officials – NGA Center agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
2023-005 - Internal Control Over Compliance and Compliance – Reporting (Preparation of the Schedule of Expenditures of Federal Awards) Program- U.S. Department of Energy, National Forum for State and Territorial Chief Executives - HHS OA, Yr 10 and Yr 11, National Forum ALN: 93.528, Award #: 2U98OA09028, Award Year: 09/01/2022 – 09/29/2023 Program- U.S. Department of Health and Human Services, Strengthening Public Health Systems and Services through National Partnerships to Improve and Protect the Nation’s Health ALN: 93.421, Award #: Various, Award Year: 08/01/2018 – 07/31/2023 Criteria – 2 CFR Section §200.510(b) states in part: “The auditee must also prepare a schedule of expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with CFR Section §200.502 Basis for determining Federal awards expended.” The schedule must provide total Federal awards expended for each individual Federal program. In accordance with §200.302 Financial Management, a non-federal entity’s financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: (1) Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. (2) Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. (3) Records that identify adequately the source and application of funds for federally-funded activities. (4) Effective control over, and accountability for, all funds, property, and other assets. Condition – The internal controls established for the review and approval of the SEFA to ensure its completeness and accuracy did not operate as designed. During our testing of management’s preparation of the SEFA, it was determined that some federal award expenditures were excluded from the original SEFA provided by management. Management subsequently corrected the SEFA to reflect the inclusion of the federal expenditures. In addition, several versions were received from management prior to the final SEFA. Questioned Costs – None. Context – This is a condition identified per review of NGA Center’s compliance with specified requirements. Cause – NGA Center only prepares the SEFA once a year in conjunction with the annual audit. This annual process lends itself to less familiarity with the processes necessary to provide a complete SEFA reporting package and turnover in key personnel historically involved in the SEFA process negatively impacted the process. Effect – Failure to present the SEFA correctly can result in incorrect major program selection and incorrect reporting to federal agencies. The finding identified was not of a magnitude to impact BDO’s selection of major programs. Repeat Finding – This is not a repeat finding. Recommendation - We recommend management continue to focus on training for both preparer and reviewer of the SEFA to ensure the documented policies and procedures can be performed as prescribed to comply with Section §200.510(b). This will ensure that the SEFA provides all relevant information as prescribed. Views of Responsible Officials – NGA Center agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
2023-005 - Internal Control Over Compliance and Compliance – Reporting (Preparation of the Schedule of Expenditures of Federal Awards) Program- U.S. Department of Energy, National Forum for State and Territorial Chief Executives - HHS OA, Yr 10 and Yr 11, National Forum ALN: 93.528, Award #: 2U98OA09028, Award Year: 09/01/2022 – 09/29/2023 Program- U.S. Department of Health and Human Services, Strengthening Public Health Systems and Services through National Partnerships to Improve and Protect the Nation’s Health ALN: 93.421, Award #: Various, Award Year: 08/01/2018 – 07/31/2023 Criteria – 2 CFR Section §200.510(b) states in part: “The auditee must also prepare a schedule of expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with CFR Section §200.502 Basis for determining Federal awards expended.” The schedule must provide total Federal awards expended for each individual Federal program. In accordance with §200.302 Financial Management, a non-federal entity’s financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: (1) Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. (2) Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. (3) Records that identify adequately the source and application of funds for federally-funded activities. (4) Effective control over, and accountability for, all funds, property, and other assets. Condition – The internal controls established for the review and approval of the SEFA to ensure its completeness and accuracy did not operate as designed. During our testing of management’s preparation of the SEFA, it was determined that some federal award expenditures were excluded from the original SEFA provided by management. Management subsequently corrected the SEFA to reflect the inclusion of the federal expenditures. In addition, several versions were received from management prior to the final SEFA. Questioned Costs – None. Context – This is a condition identified per review of NGA Center’s compliance with specified requirements. Cause – NGA Center only prepares the SEFA once a year in conjunction with the annual audit. This annual process lends itself to less familiarity with the processes necessary to provide a complete SEFA reporting package and turnover in key personnel historically involved in the SEFA process negatively impacted the process. Effect – Failure to present the SEFA correctly can result in incorrect major program selection and incorrect reporting to federal agencies. The finding identified was not of a magnitude to impact BDO’s selection of major programs. Repeat Finding – This is not a repeat finding. Recommendation - We recommend management continue to focus on training for both preparer and reviewer of the SEFA to ensure the documented policies and procedures can be performed as prescribed to comply with Section §200.510(b). This will ensure that the SEFA provides all relevant information as prescribed. Views of Responsible Officials – NGA Center agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
2023-005 - Internal Control Over Compliance and Compliance – Reporting (Preparation of the Schedule of Expenditures of Federal Awards) Program- U.S. Department of Energy, National Forum for State and Territorial Chief Executives - HHS OA, Yr 10 and Yr 11, National Forum ALN: 93.528, Award #: 2U98OA09028, Award Year: 09/01/2022 – 09/29/2023 Program- U.S. Department of Health and Human Services, Strengthening Public Health Systems and Services through National Partnerships to Improve and Protect the Nation’s Health ALN: 93.421, Award #: Various, Award Year: 08/01/2018 – 07/31/2023 Criteria – 2 CFR Section §200.510(b) states in part: “The auditee must also prepare a schedule of expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with CFR Section §200.502 Basis for determining Federal awards expended.” The schedule must provide total Federal awards expended for each individual Federal program. In accordance with §200.302 Financial Management, a non-federal entity’s financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: (1) Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. (2) Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. (3) Records that identify adequately the source and application of funds for federally-funded activities. (4) Effective control over, and accountability for, all funds, property, and other assets. Condition – The internal controls established for the review and approval of the SEFA to ensure its completeness and accuracy did not operate as designed. During our testing of management’s preparation of the SEFA, it was determined that some federal award expenditures were excluded from the original SEFA provided by management. Management subsequently corrected the SEFA to reflect the inclusion of the federal expenditures. In addition, several versions were received from management prior to the final SEFA. Questioned Costs – None. Context – This is a condition identified per review of NGA Center’s compliance with specified requirements. Cause – NGA Center only prepares the SEFA once a year in conjunction with the annual audit. This annual process lends itself to less familiarity with the processes necessary to provide a complete SEFA reporting package and turnover in key personnel historically involved in the SEFA process negatively impacted the process. Effect – Failure to present the SEFA correctly can result in incorrect major program selection and incorrect reporting to federal agencies. The finding identified was not of a magnitude to impact BDO’s selection of major programs. Repeat Finding – This is not a repeat finding. Recommendation - We recommend management continue to focus on training for both preparer and reviewer of the SEFA to ensure the documented policies and procedures can be performed as prescribed to comply with Section §200.510(b). This will ensure that the SEFA provides all relevant information as prescribed. Views of Responsible Officials – NGA Center agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
2023-005 - Internal Control Over Compliance and Compliance – Reporting (Preparation of the Schedule of Expenditures of Federal Awards) Program- U.S. Department of Energy, National Forum for State and Territorial Chief Executives - HHS OA, Yr 10 and Yr 11, National Forum ALN: 93.528, Award #: 2U98OA09028, Award Year: 09/01/2022 – 09/29/2023 Program- U.S. Department of Health and Human Services, Strengthening Public Health Systems and Services through National Partnerships to Improve and Protect the Nation’s Health ALN: 93.421, Award #: Various, Award Year: 08/01/2018 – 07/31/2023 Criteria – 2 CFR Section §200.510(b) states in part: “The auditee must also prepare a schedule of expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with CFR Section §200.502 Basis for determining Federal awards expended.” The schedule must provide total Federal awards expended for each individual Federal program. In accordance with §200.302 Financial Management, a non-federal entity’s financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: (1) Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. (2) Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. (3) Records that identify adequately the source and application of funds for federally-funded activities. (4) Effective control over, and accountability for, all funds, property, and other assets. Condition – The internal controls established for the review and approval of the SEFA to ensure its completeness and accuracy did not operate as designed. During our testing of management’s preparation of the SEFA, it was determined that some federal award expenditures were excluded from the original SEFA provided by management. Management subsequently corrected the SEFA to reflect the inclusion of the federal expenditures. In addition, several versions were received from management prior to the final SEFA. Questioned Costs – None. Context – This is a condition identified per review of NGA Center’s compliance with specified requirements. Cause – NGA Center only prepares the SEFA once a year in conjunction with the annual audit. This annual process lends itself to less familiarity with the processes necessary to provide a complete SEFA reporting package and turnover in key personnel historically involved in the SEFA process negatively impacted the process. Effect – Failure to present the SEFA correctly can result in incorrect major program selection and incorrect reporting to federal agencies. The finding identified was not of a magnitude to impact BDO’s selection of major programs. Repeat Finding – This is not a repeat finding. Recommendation - We recommend management continue to focus on training for both preparer and reviewer of the SEFA to ensure the documented policies and procedures can be performed as prescribed to comply with Section §200.510(b). This will ensure that the SEFA provides all relevant information as prescribed. Views of Responsible Officials – NGA Center agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
2023-005 - Internal Control Over Compliance and Compliance – Reporting (Preparation of the Schedule of Expenditures of Federal Awards) Program- U.S. Department of Energy, National Forum for State and Territorial Chief Executives - HHS OA, Yr 10 and Yr 11, National Forum ALN: 93.528, Award #: 2U98OA09028, Award Year: 09/01/2022 – 09/29/2023 Program- U.S. Department of Health and Human Services, Strengthening Public Health Systems and Services through National Partnerships to Improve and Protect the Nation’s Health ALN: 93.421, Award #: Various, Award Year: 08/01/2018 – 07/31/2023 Criteria – 2 CFR Section §200.510(b) states in part: “The auditee must also prepare a schedule of expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with CFR Section §200.502 Basis for determining Federal awards expended.” The schedule must provide total Federal awards expended for each individual Federal program. In accordance with §200.302 Financial Management, a non-federal entity’s financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: (1) Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. (2) Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. (3) Records that identify adequately the source and application of funds for federally-funded activities. (4) Effective control over, and accountability for, all funds, property, and other assets. Condition – The internal controls established for the review and approval of the SEFA to ensure its completeness and accuracy did not operate as designed. During our testing of management’s preparation of the SEFA, it was determined that some federal award expenditures were excluded from the original SEFA provided by management. Management subsequently corrected the SEFA to reflect the inclusion of the federal expenditures. In addition, several versions were received from management prior to the final SEFA. Questioned Costs – None. Context – This is a condition identified per review of NGA Center’s compliance with specified requirements. Cause – NGA Center only prepares the SEFA once a year in conjunction with the annual audit. This annual process lends itself to less familiarity with the processes necessary to provide a complete SEFA reporting package and turnover in key personnel historically involved in the SEFA process negatively impacted the process. Effect – Failure to present the SEFA correctly can result in incorrect major program selection and incorrect reporting to federal agencies. The finding identified was not of a magnitude to impact BDO’s selection of major programs. Repeat Finding – This is not a repeat finding. Recommendation - We recommend management continue to focus on training for both preparer and reviewer of the SEFA to ensure the documented policies and procedures can be performed as prescribed to comply with Section §200.510(b). This will ensure that the SEFA provides all relevant information as prescribed. Views of Responsible Officials – NGA Center agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
Finding 2023-001 – Preparation of the Schedule of Expenditures of Federal Awards Significant Deficiency Criteria In order to have a proper basis for the single audit, the entity must have procedures in place in order to prepare an accurate Schedule of Expenditures of Federal Awards (SEFA). Condition During the audit, multiple revisions were made to the SEFA to accurately capture federal expenditures within the fiscal year under audit. These revisions were related to the amount of expenditures reported and the identification of federal programs. Cause The City did not accurately prepare SEFA in accordance with 2 CFR 200.510, therefore causing delays in the single audit and risk of inaccurate reporting. Identification as a Repeat Finding This is a new finding for fiscal year 2023. Effect Delays in the finalization of the single audit and related reporting to grantors for the fiscal year. Questioned Costs No questioned costs. Recommendation We recommend that the City document the process for how to prepare the SEFA and allow for the necessary time for a review and approval process prior to submitting the SEFA for the audit. Management’s response See attached Corrective Action Plan.
Finding 2023-001 – Preparation of the Schedule of Expenditures of Federal Awards Significant Deficiency Criteria In order to have a proper basis for the single audit, the entity must have procedures in place in order to prepare an accurate Schedule of Expenditures of Federal Awards (SEFA). Condition During the audit, multiple revisions were made to the SEFA to accurately capture federal expenditures within the fiscal year under audit. These revisions were related to the amount of expenditures reported and the identification of federal programs. Cause The City did not accurately prepare SEFA in accordance with 2 CFR 200.510, therefore causing delays in the single audit and risk of inaccurate reporting. Identification as a Repeat Finding This is a new finding for fiscal year 2023. Effect Delays in the finalization of the single audit and related reporting to grantors for the fiscal year. Questioned Costs No questioned costs. Recommendation We recommend that the City document the process for how to prepare the SEFA and allow for the necessary time for a review and approval process prior to submitting the SEFA for the audit. Management’s response See attached Corrective Action Plan.
Finding 2023-001 – Preparation of the Schedule of Expenditures of Federal Awards Significant Deficiency Criteria In order to have a proper basis for the single audit, the entity must have procedures in place in order to prepare an accurate Schedule of Expenditures of Federal Awards (SEFA). Condition During the audit, multiple revisions were made to the SEFA to accurately capture federal expenditures within the fiscal year under audit. These revisions were related to the amount of expenditures reported and the identification of federal programs. Cause The City did not accurately prepare SEFA in accordance with 2 CFR 200.510, therefore causing delays in the single audit and risk of inaccurate reporting. Identification as a Repeat Finding This is a new finding for fiscal year 2023. Effect Delays in the finalization of the single audit and related reporting to grantors for the fiscal year. Questioned Costs No questioned costs. Recommendation We recommend that the City document the process for how to prepare the SEFA and allow for the necessary time for a review and approval process prior to submitting the SEFA for the audit. Management’s response See attached Corrective Action Plan.
Finding 2023-001 – Preparation of the Schedule of Expenditures of Federal Awards Significant Deficiency Criteria In order to have a proper basis for the single audit, the entity must have procedures in place in order to prepare an accurate Schedule of Expenditures of Federal Awards (SEFA). Condition During the audit, multiple revisions were made to the SEFA to accurately capture federal expenditures within the fiscal year under audit. These revisions were related to the amount of expenditures reported and the identification of federal programs. Cause The City did not accurately prepare SEFA in accordance with 2 CFR 200.510, therefore causing delays in the single audit and risk of inaccurate reporting. Identification as a Repeat Finding This is a new finding for fiscal year 2023. Effect Delays in the finalization of the single audit and related reporting to grantors for the fiscal year. Questioned Costs No questioned costs. Recommendation We recommend that the City document the process for how to prepare the SEFA and allow for the necessary time for a review and approval process prior to submitting the SEFA for the audit. Management’s response See attached Corrective Action Plan.
Finding 2023-001 – Preparation of the Schedule of Expenditures of Federal Awards Significant Deficiency Criteria In order to have a proper basis for the single audit, the entity must have procedures in place in order to prepare an accurate Schedule of Expenditures of Federal Awards (SEFA). Condition During the audit, multiple revisions were made to the SEFA to accurately capture federal expenditures within the fiscal year under audit. These revisions were related to the amount of expenditures reported and the identification of federal programs. Cause The City did not accurately prepare SEFA in accordance with 2 CFR 200.510, therefore causing delays in the single audit and risk of inaccurate reporting. Identification as a Repeat Finding This is a new finding for fiscal year 2023. Effect Delays in the finalization of the single audit and related reporting to grantors for the fiscal year. Questioned Costs No questioned costs. Recommendation We recommend that the City document the process for how to prepare the SEFA and allow for the necessary time for a review and approval process prior to submitting the SEFA for the audit. Management’s response See attached Corrective Action Plan.
Finding 2023-001 – Preparation of the Schedule of Expenditures of Federal Awards Significant Deficiency Criteria In order to have a proper basis for the single audit, the entity must have procedures in place in order to prepare an accurate Schedule of Expenditures of Federal Awards (SEFA). Condition During the audit, multiple revisions were made to the SEFA to accurately capture federal expenditures within the fiscal year under audit. These revisions were related to the amount of expenditures reported and the identification of federal programs. Cause The City did not accurately prepare SEFA in accordance with 2 CFR 200.510, therefore causing delays in the single audit and risk of inaccurate reporting. Identification as a Repeat Finding This is a new finding for fiscal year 2023. Effect Delays in the finalization of the single audit and related reporting to grantors for the fiscal year. Questioned Costs No questioned costs. Recommendation We recommend that the City document the process for how to prepare the SEFA and allow for the necessary time for a review and approval process prior to submitting the SEFA for the audit. Management’s response See attached Corrective Action Plan.
Finding 2023-001 – Preparation of the Schedule of Expenditures of Federal Awards Significant Deficiency Criteria In order to have a proper basis for the single audit, the entity must have procedures in place in order to prepare an accurate Schedule of Expenditures of Federal Awards (SEFA). Condition During the audit, multiple revisions were made to the SEFA to accurately capture federal expenditures within the fiscal year under audit. These revisions were related to the amount of expenditures reported and the identification of federal programs. Cause The City did not accurately prepare SEFA in accordance with 2 CFR 200.510, therefore causing delays in the single audit and risk of inaccurate reporting. Identification as a Repeat Finding This is a new finding for fiscal year 2023. Effect Delays in the finalization of the single audit and related reporting to grantors for the fiscal year. Questioned Costs No questioned costs. Recommendation We recommend that the City document the process for how to prepare the SEFA and allow for the necessary time for a review and approval process prior to submitting the SEFA for the audit. Management’s response See attached Corrective Action Plan.
Finding 2023-001 – Preparation of the Schedule of Expenditures of Federal Awards Significant Deficiency Criteria In order to have a proper basis for the single audit, the entity must have procedures in place in order to prepare an accurate Schedule of Expenditures of Federal Awards (SEFA). Condition During the audit, multiple revisions were made to the SEFA to accurately capture federal expenditures within the fiscal year under audit. These revisions were related to the amount of expenditures reported and the identification of federal programs. Cause The City did not accurately prepare SEFA in accordance with 2 CFR 200.510, therefore causing delays in the single audit and risk of inaccurate reporting. Identification as a Repeat Finding This is a new finding for fiscal year 2023. Effect Delays in the finalization of the single audit and related reporting to grantors for the fiscal year. Questioned Costs No questioned costs. Recommendation We recommend that the City document the process for how to prepare the SEFA and allow for the necessary time for a review and approval process prior to submitting the SEFA for the audit. Management’s response See attached Corrective Action Plan.
Finding 2023-02 – Preparation of SEFA (Material Weakness) Program: All Assistance Listing (AL) No.: N/A Federal Agency: N/A Passed Through: N/A Award Year: Fiscal Year 2022-2023 Compliance Requirement: N/A Questioned Costs: None 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 Agency) must prepare a SEFA for the period covered by the auditee’s financial statements, which must include the total federal awards expended as determined in accordance with §200.502. In addition, §200.303 of the Uniform Guidance states that the Agency must establish and maintain effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts. Condition During audit procedures performed over the SEFA, we noted that the Agency incorrectly excluded expenditures from AL No. 20.509 Formula Grants for Rural Areas and Tribal Transit Program in the amount of $2,533,398 and from AL No. 21.019 in the amount of $200,000 on its preliminary SEFA. Cause of Condition The Agencies’ existing internal control system is not designed to provide an accurate and complete SEFA. The procedures currently in place did not include sufficient review of the information and supporting documentation relating to federal awards before the SEFA was provided to the external auditors. The first version of the SEFA provided by the Agency reported total expenditures of $6,430,319; the final revised expenditures totaled $9,163,717. Effect of Condition The SEFA, which is prepared by the Agency and considered supplementary information to the financial statements, is a key part of the reporting package required by the Uniform Guidance. The SEFA also serves as the primary basis that the external auditors use to determine which programs will be audited as part of the single audit; therefore, the Agency’s responsibility for preparing an accurate and complete SEFA is critical. The inability to properly identify and track federal expenditures in the SEFA increases the likelihood that federal expenditures would not be fairly reported. There is increased risk of noncompliance with the requirements set forth in the U.S. Office of Management and Budget (OMB) Compliance Supplement, which can jeopardize future federal funding as well as result in the payback of federal awards. Recommendation We recommend the Agency implement internal controls to ensure the accuracy of program information, expenditure amounts, and assistance listing numbers. We also recommend the Agency strengthen its year-end closing procedures to ensure that all transactions and federal awards related to the fiscal year are properly captured and recorded in the general ledger to ensure the accuracy and completeness of the financial statements and supplementary schedules. Additionally, we recommend that the Agency provide sufficient resources and adequate oversight within the Agency to oversee the year-end closing procedures and preparation of the financial statements and supporting schedules. Lastly, we recommend the Agency Office provide training on an as needed basis for employees with financial reporting responsibilities. Management Response and Corrective Action Plan Noted and management concurs. A few measures have begun to take place chief among which is that 3rd party organization(s) are no longer managing the budget for TCRTA. As of FY 2024-2025 (July 1, 2024) TCRTA will be managing its own internal finances and thus establish sufficient controls. This report will be shared with the Board of Directors, other stakeholders, and, Tulare County’s Treasury’s office in order to obtain resources toward the net goal of fulfilling these defects. With respect to this corrective action plan TCRTA has setup a meeting with the Tresury’s office to discuss what the County’s YE closing processes are so that TCRTA can mirror the same.
Finding 2023-02 – Preparation of SEFA (Material Weakness) Program: All Assistance Listing (AL) No.: N/A Federal Agency: N/A Passed Through: N/A Award Year: Fiscal Year 2022-2023 Compliance Requirement: N/A Questioned Costs: None 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 Agency) must prepare a SEFA for the period covered by the auditee’s financial statements, which must include the total federal awards expended as determined in accordance with §200.502. In addition, §200.303 of the Uniform Guidance states that the Agency must establish and maintain effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts. Condition During audit procedures performed over the SEFA, we noted that the Agency incorrectly excluded expenditures from AL No. 20.509 Formula Grants for Rural Areas and Tribal Transit Program in the amount of $2,533,398 and from AL No. 21.019 in the amount of $200,000 on its preliminary SEFA. Cause of Condition The Agencies’ existing internal control system is not designed to provide an accurate and complete SEFA. The procedures currently in place did not include sufficient review of the information and supporting documentation relating to federal awards before the SEFA was provided to the external auditors. The first version of the SEFA provided by the Agency reported total expenditures of $6,430,319; the final revised expenditures totaled $9,163,717. Effect of Condition The SEFA, which is prepared by the Agency and considered supplementary information to the financial statements, is a key part of the reporting package required by the Uniform Guidance. The SEFA also serves as the primary basis that the external auditors use to determine which programs will be audited as part of the single audit; therefore, the Agency’s responsibility for preparing an accurate and complete SEFA is critical. The inability to properly identify and track federal expenditures in the SEFA increases the likelihood that federal expenditures would not be fairly reported. There is increased risk of noncompliance with the requirements set forth in the U.S. Office of Management and Budget (OMB) Compliance Supplement, which can jeopardize future federal funding as well as result in the payback of federal awards. Recommendation We recommend the Agency implement internal controls to ensure the accuracy of program information, expenditure amounts, and assistance listing numbers. We also recommend the Agency strengthen its year-end closing procedures to ensure that all transactions and federal awards related to the fiscal year are properly captured and recorded in the general ledger to ensure the accuracy and completeness of the financial statements and supplementary schedules. Additionally, we recommend that the Agency provide sufficient resources and adequate oversight within the Agency to oversee the year-end closing procedures and preparation of the financial statements and supporting schedules. Lastly, we recommend the Agency Office provide training on an as needed basis for employees with financial reporting responsibilities. Management Response and Corrective Action Plan Noted and management concurs. A few measures have begun to take place chief among which is that 3rd party organization(s) are no longer managing the budget for TCRTA. As of FY 2024-2025 (July 1, 2024) TCRTA will be managing its own internal finances and thus establish sufficient controls. This report will be shared with the Board of Directors, other stakeholders, and, Tulare County’s Treasury’s office in order to obtain resources toward the net goal of fulfilling these defects. With respect to this corrective action plan TCRTA has setup a meeting with the Tresury’s office to discuss what the County’s YE closing processes are so that TCRTA can mirror the same.
Finding 2023-02 – Preparation of SEFA (Material Weakness) Program: All Assistance Listing (AL) No.: N/A Federal Agency: N/A Passed Through: N/A Award Year: Fiscal Year 2022-2023 Compliance Requirement: N/A Questioned Costs: None 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 Agency) must prepare a SEFA for the period covered by the auditee’s financial statements, which must include the total federal awards expended as determined in accordance with §200.502. In addition, §200.303 of the Uniform Guidance states that the Agency must establish and maintain effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts. Condition During audit procedures performed over the SEFA, we noted that the Agency incorrectly excluded expenditures from AL No. 20.509 Formula Grants for Rural Areas and Tribal Transit Program in the amount of $2,533,398 and from AL No. 21.019 in the amount of $200,000 on its preliminary SEFA. Cause of Condition The Agencies’ existing internal control system is not designed to provide an accurate and complete SEFA. The procedures currently in place did not include sufficient review of the information and supporting documentation relating to federal awards before the SEFA was provided to the external auditors. The first version of the SEFA provided by the Agency reported total expenditures of $6,430,319; the final revised expenditures totaled $9,163,717. Effect of Condition The SEFA, which is prepared by the Agency and considered supplementary information to the financial statements, is a key part of the reporting package required by the Uniform Guidance. The SEFA also serves as the primary basis that the external auditors use to determine which programs will be audited as part of the single audit; therefore, the Agency’s responsibility for preparing an accurate and complete SEFA is critical. The inability to properly identify and track federal expenditures in the SEFA increases the likelihood that federal expenditures would not be fairly reported. There is increased risk of noncompliance with the requirements set forth in the U.S. Office of Management and Budget (OMB) Compliance Supplement, which can jeopardize future federal funding as well as result in the payback of federal awards. Recommendation We recommend the Agency implement internal controls to ensure the accuracy of program information, expenditure amounts, and assistance listing numbers. We also recommend the Agency strengthen its year-end closing procedures to ensure that all transactions and federal awards related to the fiscal year are properly captured and recorded in the general ledger to ensure the accuracy and completeness of the financial statements and supplementary schedules. Additionally, we recommend that the Agency provide sufficient resources and adequate oversight within the Agency to oversee the year-end closing procedures and preparation of the financial statements and supporting schedules. Lastly, we recommend the Agency Office provide training on an as needed basis for employees with financial reporting responsibilities. Management Response and Corrective Action Plan Noted and management concurs. A few measures have begun to take place chief among which is that 3rd party organization(s) are no longer managing the budget for TCRTA. As of FY 2024-2025 (July 1, 2024) TCRTA will be managing its own internal finances and thus establish sufficient controls. This report will be shared with the Board of Directors, other stakeholders, and, Tulare County’s Treasury’s office in order to obtain resources toward the net goal of fulfilling these defects. With respect to this corrective action plan TCRTA has setup a meeting with the Tresury’s office to discuss what the County’s YE closing processes are so that TCRTA can mirror the same.
Finding 2023-02 – Preparation of SEFA (Material Weakness) Program: All Assistance Listing (AL) No.: N/A Federal Agency: N/A Passed Through: N/A Award Year: Fiscal Year 2022-2023 Compliance Requirement: N/A Questioned Costs: None 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 Agency) must prepare a SEFA for the period covered by the auditee’s financial statements, which must include the total federal awards expended as determined in accordance with §200.502. In addition, §200.303 of the Uniform Guidance states that the Agency must establish and maintain effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts. Condition During audit procedures performed over the SEFA, we noted that the Agency incorrectly excluded expenditures from AL No. 20.509 Formula Grants for Rural Areas and Tribal Transit Program in the amount of $2,533,398 and from AL No. 21.019 in the amount of $200,000 on its preliminary SEFA. Cause of Condition The Agencies’ existing internal control system is not designed to provide an accurate and complete SEFA. The procedures currently in place did not include sufficient review of the information and supporting documentation relating to federal awards before the SEFA was provided to the external auditors. The first version of the SEFA provided by the Agency reported total expenditures of $6,430,319; the final revised expenditures totaled $9,163,717. Effect of Condition The SEFA, which is prepared by the Agency and considered supplementary information to the financial statements, is a key part of the reporting package required by the Uniform Guidance. The SEFA also serves as the primary basis that the external auditors use to determine which programs will be audited as part of the single audit; therefore, the Agency’s responsibility for preparing an accurate and complete SEFA is critical. The inability to properly identify and track federal expenditures in the SEFA increases the likelihood that federal expenditures would not be fairly reported. There is increased risk of noncompliance with the requirements set forth in the U.S. Office of Management and Budget (OMB) Compliance Supplement, which can jeopardize future federal funding as well as result in the payback of federal awards. Recommendation We recommend the Agency implement internal controls to ensure the accuracy of program information, expenditure amounts, and assistance listing numbers. We also recommend the Agency strengthen its year-end closing procedures to ensure that all transactions and federal awards related to the fiscal year are properly captured and recorded in the general ledger to ensure the accuracy and completeness of the financial statements and supplementary schedules. Additionally, we recommend that the Agency provide sufficient resources and adequate oversight within the Agency to oversee the year-end closing procedures and preparation of the financial statements and supporting schedules. Lastly, we recommend the Agency Office provide training on an as needed basis for employees with financial reporting responsibilities. Management Response and Corrective Action Plan Noted and management concurs. A few measures have begun to take place chief among which is that 3rd party organization(s) are no longer managing the budget for TCRTA. As of FY 2024-2025 (July 1, 2024) TCRTA will be managing its own internal finances and thus establish sufficient controls. This report will be shared with the Board of Directors, other stakeholders, and, Tulare County’s Treasury’s office in order to obtain resources toward the net goal of fulfilling these defects. With respect to this corrective action plan TCRTA has setup a meeting with the Tresury’s office to discuss what the County’s YE closing processes are so that TCRTA can mirror the same.
Finding 2023-02 – Preparation of SEFA (Material Weakness) Program: All Assistance Listing (AL) No.: N/A Federal Agency: N/A Passed Through: N/A Award Year: Fiscal Year 2022-2023 Compliance Requirement: N/A Questioned Costs: None 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 Agency) must prepare a SEFA for the period covered by the auditee’s financial statements, which must include the total federal awards expended as determined in accordance with §200.502. In addition, §200.303 of the Uniform Guidance states that the Agency must establish and maintain effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts. Condition During audit procedures performed over the SEFA, we noted that the Agency incorrectly excluded expenditures from AL No. 20.509 Formula Grants for Rural Areas and Tribal Transit Program in the amount of $2,533,398 and from AL No. 21.019 in the amount of $200,000 on its preliminary SEFA. Cause of Condition The Agencies’ existing internal control system is not designed to provide an accurate and complete SEFA. The procedures currently in place did not include sufficient review of the information and supporting documentation relating to federal awards before the SEFA was provided to the external auditors. The first version of the SEFA provided by the Agency reported total expenditures of $6,430,319; the final revised expenditures totaled $9,163,717. Effect of Condition The SEFA, which is prepared by the Agency and considered supplementary information to the financial statements, is a key part of the reporting package required by the Uniform Guidance. The SEFA also serves as the primary basis that the external auditors use to determine which programs will be audited as part of the single audit; therefore, the Agency’s responsibility for preparing an accurate and complete SEFA is critical. The inability to properly identify and track federal expenditures in the SEFA increases the likelihood that federal expenditures would not be fairly reported. There is increased risk of noncompliance with the requirements set forth in the U.S. Office of Management and Budget (OMB) Compliance Supplement, which can jeopardize future federal funding as well as result in the payback of federal awards. Recommendation We recommend the Agency implement internal controls to ensure the accuracy of program information, expenditure amounts, and assistance listing numbers. We also recommend the Agency strengthen its year-end closing procedures to ensure that all transactions and federal awards related to the fiscal year are properly captured and recorded in the general ledger to ensure the accuracy and completeness of the financial statements and supplementary schedules. Additionally, we recommend that the Agency provide sufficient resources and adequate oversight within the Agency to oversee the year-end closing procedures and preparation of the financial statements and supporting schedules. Lastly, we recommend the Agency Office provide training on an as needed basis for employees with financial reporting responsibilities. Management Response and Corrective Action Plan Noted and management concurs. A few measures have begun to take place chief among which is that 3rd party organization(s) are no longer managing the budget for TCRTA. As of FY 2024-2025 (July 1, 2024) TCRTA will be managing its own internal finances and thus establish sufficient controls. This report will be shared with the Board of Directors, other stakeholders, and, Tulare County’s Treasury’s office in order to obtain resources toward the net goal of fulfilling these defects. With respect to this corrective action plan TCRTA has setup a meeting with the Tresury’s office to discuss what the County’s YE closing processes are so that TCRTA can mirror the same.
Finding 2023-02 – Preparation of SEFA (Material Weakness) Program: All Assistance Listing (AL) No.: N/A Federal Agency: N/A Passed Through: N/A Award Year: Fiscal Year 2022-2023 Compliance Requirement: N/A Questioned Costs: None 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 Agency) must prepare a SEFA for the period covered by the auditee’s financial statements, which must include the total federal awards expended as determined in accordance with §200.502. In addition, §200.303 of the Uniform Guidance states that the Agency must establish and maintain effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts. Condition During audit procedures performed over the SEFA, we noted that the Agency incorrectly excluded expenditures from AL No. 20.509 Formula Grants for Rural Areas and Tribal Transit Program in the amount of $2,533,398 and from AL No. 21.019 in the amount of $200,000 on its preliminary SEFA. Cause of Condition The Agencies’ existing internal control system is not designed to provide an accurate and complete SEFA. The procedures currently in place did not include sufficient review of the information and supporting documentation relating to federal awards before the SEFA was provided to the external auditors. The first version of the SEFA provided by the Agency reported total expenditures of $6,430,319; the final revised expenditures totaled $9,163,717. Effect of Condition The SEFA, which is prepared by the Agency and considered supplementary information to the financial statements, is a key part of the reporting package required by the Uniform Guidance. The SEFA also serves as the primary basis that the external auditors use to determine which programs will be audited as part of the single audit; therefore, the Agency’s responsibility for preparing an accurate and complete SEFA is critical. The inability to properly identify and track federal expenditures in the SEFA increases the likelihood that federal expenditures would not be fairly reported. There is increased risk of noncompliance with the requirements set forth in the U.S. Office of Management and Budget (OMB) Compliance Supplement, which can jeopardize future federal funding as well as result in the payback of federal awards. Recommendation We recommend the Agency implement internal controls to ensure the accuracy of program information, expenditure amounts, and assistance listing numbers. We also recommend the Agency strengthen its year-end closing procedures to ensure that all transactions and federal awards related to the fiscal year are properly captured and recorded in the general ledger to ensure the accuracy and completeness of the financial statements and supplementary schedules. Additionally, we recommend that the Agency provide sufficient resources and adequate oversight within the Agency to oversee the year-end closing procedures and preparation of the financial statements and supporting schedules. Lastly, we recommend the Agency Office provide training on an as needed basis for employees with financial reporting responsibilities. Management Response and Corrective Action Plan Noted and management concurs. A few measures have begun to take place chief among which is that 3rd party organization(s) are no longer managing the budget for TCRTA. As of FY 2024-2025 (July 1, 2024) TCRTA will be managing its own internal finances and thus establish sufficient controls. This report will be shared with the Board of Directors, other stakeholders, and, Tulare County’s Treasury’s office in order to obtain resources toward the net goal of fulfilling these defects. With respect to this corrective action plan TCRTA has setup a meeting with the Tresury’s office to discuss what the County’s YE closing processes are so that TCRTA can mirror the same.
Internal Control over Compliance and Compliance with Reporting (Preparation of the Schedule of Expenditures of Federal Awards (SEFA)) ALN: 10.170, Specialty Crop Block Grant ALN: 15.228, National Fire Plan ALN 10.767: Intermediary Relending Program (IRP) ALN 66.818: Brownfields RLF ALN 11.307: Economic Development Assistance RLF 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 Specialty Crop Block Grant was left off of the prepared SEFA. Amounts reported for the National Fire Plan grant, IRP, and Brownfields RLF did not agree to the accounting records. The amount reported for the Economic Development Assistance RLF was not calculated in accordance with the compliance supplement calculation formula. Context: There SEFA was understated or overstated by ALN as follows: • Understated by $14,123 for the omission of the Specialty Crop Block Grant; • Overstated by $1,942 for National Fire Plan grant; • Understated by $10,748 for IRP; • Understated by $25,902 for Brownfields RLF; and • Overstated by $101,804 for Economic Development Assistance RLF. The net effect was an overstatement of $52,973. Effect: The SEFA provided was not complete and fully 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. Auditor Recommendation: We recommend the Organization prepare 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 staff who administer federal funds review the SEFA for completeness and accuracy before providing it to the auditor. Organization Response: The organization disagrees with the reported deficiency related to the SEFA preparation on the basis that the task was an agreed nonattest service contracted to Douglas Wilson & Company, P.C. The noted modifications are outcomes of these services and are not indicative of control deficiencies. With respect to the nonattest services, the Organization has fulfilled the responsibilities stated in the engagement letter to assume all management responsibilities for the services; to have those services overseen by an individual with appropriate skills, knowledge, and experience; evaluate the adequacy of the services; and to accept responsibility for them. Since its inception, the organization’s auditors have prepared the SEFA under the same engagement letters executed with the auditor. The organization’s outsourced accounting firm, JCCS, also provides these nonattest services for their auditees and were operating under the same understanding of this service arrangement. Management reports that this finding is a result of a misunderstanding between Management, JCCS, and Douglas Wilson & Company, P.C. regarding which party would complete the SEFA. Based on the signed engagement letter, Management understood that completing the SEFA was part of the auditors’ nonattest services. Their outsourced accounting firm, JCCS, provided a draft SEFA to the auditors with communication that it was a draft and would need to be finalized. JCCS worked directly with the auditor in making the necessary changes and finalizing the SEFA. Management nor JCCS were aware that the auditor would be identifying this collaboration as a material weakness. Management strongly disagrees that this finding has anything to do with a deficiency in internal controls as they understood they had engaged the auditor to provide this nonattest service. Management reports a discussion with the auditor that such a misunderstanding presented as an internal control deficiency carries significant consequences for the organization's future Federal awards. It is important that the organization's Federal grantors understand the full context of this finding.
MATERIAL WEAKNESS IN INTERNAL CONTROL OVER COMPLIANCE – SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS 2023-005 Reporting Compliance Requirement Criteria – 2 CFR § 200.510 requires that the Academy prepare appropriate financial statements, including the Schedule of Expenditures of Federal Awards (SEFA) for the year ended June 30, 2023, which must include the total federal awards expended as determined in accordance with 2 CFR § 200.502. Management is responsible for establishing and maintaining effective internal controls over compliance with requirements applicable to federal programs, including separately tracking federal expenditures within the finance system to provide for accurate preparation of the SEFA. Condition – During our audit, we noted the Academy did not have sufficient controls in place to ensure completeness of the SEFA and compliance with this requirement. The Academy’s SEFA was understated by $158,815 in federal expenditures related to the Emergency Connectivity Fund federal program. Questioned Costs – Not applicable. Context – On the June 30, 2023 SEFA, $158,815 of $1,308,178 was initially not reported. Cause – This was an oversight by academy personnel. Repeat Finding – This is a current year finding. Effect – An incomplete SEFA could result in incorrect major program determination and could be seen as a violation of federal award agreements. Recommendation – We recommend that the Academy review its internal control procedures over reporting and verify completeness of expenditures reported on the SEFA in the future. View of Responsible Official and Planned Corrective Actions – The Academy agrees with the finding. The Academy has separately issued a Corrective Action Plan related to this finding.
MATERIAL WEAKNESS IN INTERNAL CONTROL OVER COMPLIANCE – SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS 2023-005 Reporting Compliance Requirement Criteria – 2 CFR § 200.510 requires that the Academy prepare appropriate financial statements, including the Schedule of Expenditures of Federal Awards (SEFA) for the year ended June 30, 2023, which must include the total federal awards expended as determined in accordance with 2 CFR § 200.502. Management is responsible for establishing and maintaining effective internal controls over compliance with requirements applicable to federal programs, including separately tracking federal expenditures within the finance system to provide for accurate preparation of the SEFA. Condition – During our audit, we noted the Academy did not have sufficient controls in place to ensure completeness of the SEFA and compliance with this requirement. The Academy’s SEFA was understated by $158,815 in federal expenditures related to the Emergency Connectivity Fund federal program. Questioned Costs – Not applicable. Context – On the June 30, 2023 SEFA, $158,815 of $1,308,178 was initially not reported. Cause – This was an oversight by academy personnel. Repeat Finding – This is a current year finding. Effect – An incomplete SEFA could result in incorrect major program determination and could be seen as a violation of federal award agreements. Recommendation – We recommend that the Academy review its internal control procedures over reporting and verify completeness of expenditures reported on the SEFA in the future. View of Responsible Official and Planned Corrective Actions – The Academy agrees with the finding. The Academy has separately issued a Corrective Action Plan related to this finding.
MATERIAL WEAKNESS IN INTERNAL CONTROL OVER COMPLIANCE – SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS 2023-005 Reporting Compliance Requirement Criteria – 2 CFR § 200.510 requires that the Academy prepare appropriate financial statements, including the Schedule of Expenditures of Federal Awards (SEFA) for the year ended June 30, 2023, which must include the total federal awards expended as determined in accordance with 2 CFR § 200.502. Management is responsible for establishing and maintaining effective internal controls over compliance with requirements applicable to federal programs, including separately tracking federal expenditures within the finance system to provide for accurate preparation of the SEFA. Condition – During our audit, we noted the Academy did not have sufficient controls in place to ensure completeness of the SEFA and compliance with this requirement. The Academy’s SEFA was understated by $158,815 in federal expenditures related to the Emergency Connectivity Fund federal program. Questioned Costs – Not applicable. Context – On the June 30, 2023 SEFA, $158,815 of $1,308,178 was initially not reported. Cause – This was an oversight by academy personnel. Repeat Finding – This is a current year finding. Effect – An incomplete SEFA could result in incorrect major program determination and could be seen as a violation of federal award agreements. Recommendation – We recommend that the Academy review its internal control procedures over reporting and verify completeness of expenditures reported on the SEFA in the future. View of Responsible Official and Planned Corrective Actions – The Academy agrees with the finding. The Academy has separately issued a Corrective Action Plan related to this finding.
MATERIAL WEAKNESS IN INTERNAL CONTROL OVER COMPLIANCE – SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS 2023-005 Reporting Compliance Requirement Criteria – 2 CFR § 200.510 requires that the Academy prepare appropriate financial statements, including the Schedule of Expenditures of Federal Awards (SEFA) for the year ended June 30, 2023, which must include the total federal awards expended as determined in accordance with 2 CFR § 200.502. Management is responsible for establishing and maintaining effective internal controls over compliance with requirements applicable to federal programs, including separately tracking federal expenditures within the finance system to provide for accurate preparation of the SEFA. Condition – During our audit, we noted the Academy did not have sufficient controls in place to ensure completeness of the SEFA and compliance with this requirement. The Academy’s SEFA was understated by $158,815 in federal expenditures related to the Emergency Connectivity Fund federal program. Questioned Costs – Not applicable. Context – On the June 30, 2023 SEFA, $158,815 of $1,308,178 was initially not reported. Cause – This was an oversight by academy personnel. Repeat Finding – This is a current year finding. Effect – An incomplete SEFA could result in incorrect major program determination and could be seen as a violation of federal award agreements. Recommendation – We recommend that the Academy review its internal control procedures over reporting and verify completeness of expenditures reported on the SEFA in the future. View of Responsible Official and Planned Corrective Actions – The Academy agrees with the finding. The Academy has separately issued a Corrective Action Plan related to this finding.
MATERIAL WEAKNESS IN INTERNAL CONTROL OVER COMPLIANCE – SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS 2023-005 Reporting Compliance Requirement Criteria – 2 CFR § 200.510 requires that the Academy prepare appropriate financial statements, including the Schedule of Expenditures of Federal Awards (SEFA) for the year ended June 30, 2023, which must include the total federal awards expended as determined in accordance with 2 CFR § 200.502. Management is responsible for establishing and maintaining effective internal controls over compliance with requirements applicable to federal programs, including separately tracking federal expenditures within the finance system to provide for accurate preparation of the SEFA. Condition – During our audit, we noted the Academy did not have sufficient controls in place to ensure completeness of the SEFA and compliance with this requirement. The Academy’s SEFA was understated by $158,815 in federal expenditures related to the Emergency Connectivity Fund federal program. Questioned Costs – Not applicable. Context – On the June 30, 2023 SEFA, $158,815 of $1,308,178 was initially not reported. Cause – This was an oversight by academy personnel. Repeat Finding – This is a current year finding. Effect – An incomplete SEFA could result in incorrect major program determination and could be seen as a violation of federal award agreements. Recommendation – We recommend that the Academy review its internal control procedures over reporting and verify completeness of expenditures reported on the SEFA in the future. View of Responsible Official and Planned Corrective Actions – The Academy agrees with the finding. The Academy has separately issued a Corrective Action Plan related to this finding.