2022-001 ? Rent Reasonableness Federal Program Information: Department of Housing and Urban Development ? Housing Voucher Cluster: ALN ? 14.871 Housing Choice Voucher Criteria: The following CFR(s) apply to this finding: 2 CFR 200.514(c), 2 CFR section 200.305(b)(3). Condition: During audit procedures, it was identified that the Housing Authorities rent reasonableness calculation does not establish comparability. Cause: The Housing Authority does not have the necessary internal controls over compliance. Effect: The Housing Authority does not have the correct system in place to establish comparability correct based on reasonable rent in the area. Identification of Questioned Costs: None identified. Context: The entire population of the tenants that were sampled during field work. Repeat Finding: This is not a repeat finding. Recommendation: It is recommended that the Unit implement internal control processes and procedures to ensure that reasonable rent can be established with comparability in the area. Views of Responsible Officials and Corrective Action Plan: Client agrees with finding and the unabridged version of their response can be found in the Corrective Action Plan. Please see the Corrective Action Plan issued by the Melody Ackerman.
Finding 2022-001: Significant Deficiency in Internal Control over Compliance, – Cash Management Agency: U.S. Department of Energy Award Number: DE-IE0000098 Assistance Listing Number: 81.087 Program Name: Research and Development Program Cluster: Renewable Energy Research and Development Criteria: Based on 2 CFR section § 200.514, auditors are required to test that internal controls are effective in preventing or detecting noncompliance. Management is responsible for the design, implementation, and maintenance of internal controls over compliance. There were inadequate controls over cash management. Condition: Alaska Village Electric Cooperative, Inc. and Subsidiary started drawing down on this award for the first time in the current year. A single request was made during the year for reimbursement of funds. During examination the support for request for reimbursement, there was no noncompliance identified. However, it was determined there were not sufficient review controls implemented to prevent or detect potential noncompliance with cash management requirements. Cause: The method for requesting reimbursement over the award are different than other programs operated by Alaska Village Electric Cooperative, Inc. and Subsidiary Requests are entirely electronic and controls were not originally in place to address the method of reimbursement requests. Effect or potential effect: Without sufficient review, it would be possible for funds to be requested for unallowable costs or prematurely resulting in funds not being properly tracked for potential earnings requiring repayment to the granting agency. Questioned costs: None identified. Context: In accordance with Uniform Guidance, the auditor performed inquiries with staff and management surrounding to controls and procedures surrounding the compliance requirements of the major programs. Through this inquiry it was identified that sufficient controls were not in place for cash management of the program. Identification as a repeat finding: Not applicable, not a repeat finding. Recommendation: We recommend Alaska Village Electric Cooperative, Inc. and Subsidiary develop controls procedures to ensure compliance with cash management requirements are met. Views of responsible officials: Management acknowledges the observed recommendation. New controls will be implemented to ensure proper review of requests for reimbursement are performed.
Finding 2022-001: Identification of Federal Award Compliance Requirements Assistance Listing Number: 19.510 Federal Program: U.S. Refugee Admissions Program Federal Agency: U.S. Department of State Pass-Through Entity: Church World Service Type of Finding: Material Weakness in Internal Control over Compliance Criteria: Per Title 2 of the Code of Federal Regulations (2 CFR) section 200.501, non-federal entities that expend $750,000 or more during the non-federal entity’s fiscal year in federal awards must have a Single Audit conducted in accordance with 2 CFR section 200.514. Condition: We noted Team Rubicon received a federal subaward in excess of $750,000 requiring a Single Audit. Cause: The error was primarily due to a misunderstanding of the $750,000 limit above which a Single Audit would be required. Effect or Potential Effect: A failure to identify federal compliance requirements could result in Team Rubicon not being in compliance with federal statutes, regulations and the terms and conditions of federal awards. Questioned Costs: None identified Context: During the year ended December 31, 2022, Team Rubicon received a grant in excess of $750,000 from a recipient of a federal award, making Team Rubicon a subrecipient of the award and subject to certain federal compliance requirements including a Single Audit. Repeat Finding: Not applicable Recommendation: Management is responsible for establishing controls and procedures to ensure contracts and grants are reviewed for key terms and conditions that may indicate federal funding to ensure the proper identification and compliance with federal statutes, regulations and the terms and conditions of the federal awards including the requirement for a Single Audit. Views of Responsible Official: Management agrees and acknowledges the finding.
Assistance Listing Number, Federal Agency, and Program Name: All major programs Federal Award Identification Number and Year: 2022 Finding Type – Material weakness over compliance Repeat Finding - No Criteria – Per 2 CFR 200.512 (a) (1), the audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Per 2 CFR 200.501 (b), a non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single audit conducted in accordance with § 200.514. Condition – The data collection form was not submitted within the required time as required by 2 CFR 200.512 for the year ended December 31, 2022. Context – The County’s single audit was not completed prior to the due date of data collection form. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause – The County’s Schedule of Federal Awards was not prepared in a timely manner. Effect – Data collection forms were not submitted on time. Recommendation – We recommend that the County develop a reliable system to close the financial records in a timely manner. View of Responsible Officials and Corrective Action Plan – The 2022 Single Audit was not completed within the required timeline primarily as a result of staff turnover and resource requirements surrounding the implementation of a new ERP system in 2023. New staff have been assigned to the preparation of the Schedule of Expenditures of Federal Awards (SEFA) beginning in 2023 and the new system went live in October 2023.
Assistance Listing Number, Federal Agency, and Program Name: All major programs Federal Award Identification Number and Year: 2022 Finding Type – Material weakness over compliance Repeat Finding - No Criteria – Per 2 CFR 200.512 (a) (1), the audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Per 2 CFR 200.501 (b), a non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single audit conducted in accordance with § 200.514. Condition – The data collection form was not submitted within the required time as required by 2 CFR 200.512 for the year ended December 31, 2022. Context – The County’s single audit was not completed prior to the due date of data collection form. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause – The County’s Schedule of Federal Awards was not prepared in a timely manner. Effect – Data collection forms were not submitted on time. Recommendation – We recommend that the County develop a reliable system to close the financial records in a timely manner. View of Responsible Officials and Corrective Action Plan – The 2022 Single Audit was not completed within the required timeline primarily as a result of staff turnover and resource requirements surrounding the implementation of a new ERP system in 2023. New staff have been assigned to the preparation of the Schedule of Expenditures of Federal Awards (SEFA) beginning in 2023 and the new system went live in October 2023.
Assistance Listing Number, Federal Agency, and Program Name: All major programs Federal Award Identification Number and Year: 2022 Finding Type – Material weakness over compliance Repeat Finding - No Criteria – Per 2 CFR 200.512 (a) (1), the audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Per 2 CFR 200.501 (b), a non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single audit conducted in accordance with § 200.514. Condition – The data collection form was not submitted within the required time as required by 2 CFR 200.512 for the year ended December 31, 2022. Context – The County’s single audit was not completed prior to the due date of data collection form. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause – The County’s Schedule of Federal Awards was not prepared in a timely manner. Effect – Data collection forms were not submitted on time. Recommendation – We recommend that the County develop a reliable system to close the financial records in a timely manner. View of Responsible Officials and Corrective Action Plan – The 2022 Single Audit was not completed within the required timeline primarily as a result of staff turnover and resource requirements surrounding the implementation of a new ERP system in 2023. New staff have been assigned to the preparation of the Schedule of Expenditures of Federal Awards (SEFA) beginning in 2023 and the new system went live in October 2023.
Assistance Listing Number, Federal Agency, and Program Name: All major programs Federal Award Identification Number and Year: 2022 Finding Type – Material weakness over compliance Repeat Finding - No Criteria – Per 2 CFR 200.512 (a) (1), the audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Per 2 CFR 200.501 (b), a non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single audit conducted in accordance with § 200.514. Condition – The data collection form was not submitted within the required time as required by 2 CFR 200.512 for the year ended December 31, 2022. Context – The County’s single audit was not completed prior to the due date of data collection form. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause – The County’s Schedule of Federal Awards was not prepared in a timely manner. Effect – Data collection forms were not submitted on time. Recommendation – We recommend that the County develop a reliable system to close the financial records in a timely manner. View of Responsible Officials and Corrective Action Plan – The 2022 Single Audit was not completed within the required timeline primarily as a result of staff turnover and resource requirements surrounding the implementation of a new ERP system in 2023. New staff have been assigned to the preparation of the Schedule of Expenditures of Federal Awards (SEFA) beginning in 2023 and the new system went live in October 2023.
Assistance Listing Number, Federal Agency, and Program Name: All major programs Federal Award Identification Number and Year: 2022 Finding Type – Material weakness over compliance Repeat Finding - No Criteria – Per 2 CFR 200.512 (a) (1), the audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Per 2 CFR 200.501 (b), a non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single audit conducted in accordance with § 200.514. Condition – The data collection form was not submitted within the required time as required by 2 CFR 200.512 for the year ended December 31, 2022. Context – The County’s single audit was not completed prior to the due date of data collection form. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause – The County’s Schedule of Federal Awards was not prepared in a timely manner. Effect – Data collection forms were not submitted on time. Recommendation – We recommend that the County develop a reliable system to close the financial records in a timely manner. View of Responsible Officials and Corrective Action Plan – The 2022 Single Audit was not completed within the required timeline primarily as a result of staff turnover and resource requirements surrounding the implementation of a new ERP system in 2023. New staff have been assigned to the preparation of the Schedule of Expenditures of Federal Awards (SEFA) beginning in 2023 and the new system went live in October 2023.
Assistance Listing Number, Federal Agency, and Program Name: All major programs Federal Award Identification Number and Year: 2022 Finding Type – Material weakness over compliance Repeat Finding - No Criteria – Per 2 CFR 200.512 (a) (1), the audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Per 2 CFR 200.501 (b), a non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single audit conducted in accordance with § 200.514. Condition – The data collection form was not submitted within the required time as required by 2 CFR 200.512 for the year ended December 31, 2022. Context – The County’s single audit was not completed prior to the due date of data collection form. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause – The County’s Schedule of Federal Awards was not prepared in a timely manner. Effect – Data collection forms were not submitted on time. Recommendation – We recommend that the County develop a reliable system to close the financial records in a timely manner. View of Responsible Officials and Corrective Action Plan – The 2022 Single Audit was not completed within the required timeline primarily as a result of staff turnover and resource requirements surrounding the implementation of a new ERP system in 2023. New staff have been assigned to the preparation of the Schedule of Expenditures of Federal Awards (SEFA) beginning in 2023 and the new system went live in October 2023.
Assistance Listing Number, Federal Agency, and Program Name: All major programs Federal Award Identification Number and Year: 2022 Finding Type – Material weakness over compliance Repeat Finding - No Criteria – Per 2 CFR 200.512 (a) (1), the audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Per 2 CFR 200.501 (b), a non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single audit conducted in accordance with § 200.514. Condition – The data collection form was not submitted within the required time as required by 2 CFR 200.512 for the year ended December 31, 2022. Context – The County’s single audit was not completed prior to the due date of data collection form. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause – The County’s Schedule of Federal Awards was not prepared in a timely manner. Effect – Data collection forms were not submitted on time. Recommendation – We recommend that the County develop a reliable system to close the financial records in a timely manner. View of Responsible Officials and Corrective Action Plan – The 2022 Single Audit was not completed within the required timeline primarily as a result of staff turnover and resource requirements surrounding the implementation of a new ERP system in 2023. New staff have been assigned to the preparation of the Schedule of Expenditures of Federal Awards (SEFA) beginning in 2023 and the new system went live in October 2023.
Assistance Listing Number, Federal Agency, and Program Name: All major programs Federal Award Identification Number and Year: 2022 Finding Type – Material weakness over compliance Repeat Finding - No Criteria – Per 2 CFR 200.512 (a) (1), the audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Per 2 CFR 200.501 (b), a non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single audit conducted in accordance with § 200.514. Condition – The data collection form was not submitted within the required time as required by 2 CFR 200.512 for the year ended December 31, 2022. Context – The County’s single audit was not completed prior to the due date of data collection form. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause – The County’s Schedule of Federal Awards was not prepared in a timely manner. Effect – Data collection forms were not submitted on time. Recommendation – We recommend that the County develop a reliable system to close the financial records in a timely manner. View of Responsible Officials and Corrective Action Plan – The 2022 Single Audit was not completed within the required timeline primarily as a result of staff turnover and resource requirements surrounding the implementation of a new ERP system in 2023. New staff have been assigned to the preparation of the Schedule of Expenditures of Federal Awards (SEFA) beginning in 2023 and the new system went live in October 2023.
Assistance Listing Number, Federal Agency, and Program Name: All major programs Federal Award Identification Number and Year: 2022 Finding Type – Material weakness over compliance Repeat Finding - No Criteria – Per 2 CFR 200.512 (a) (1), the audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Per 2 CFR 200.501 (b), a non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single audit conducted in accordance with § 200.514. Condition – The data collection form was not submitted within the required time as required by 2 CFR 200.512 for the year ended December 31, 2022. Context – The County’s single audit was not completed prior to the due date of data collection form. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause – The County’s Schedule of Federal Awards was not prepared in a timely manner. Effect – Data collection forms were not submitted on time. Recommendation – We recommend that the County develop a reliable system to close the financial records in a timely manner. View of Responsible Officials and Corrective Action Plan – The 2022 Single Audit was not completed within the required timeline primarily as a result of staff turnover and resource requirements surrounding the implementation of a new ERP system in 2023. New staff have been assigned to the preparation of the Schedule of Expenditures of Federal Awards (SEFA) beginning in 2023 and the new system went live in October 2023.
Assistance Listing Number, Federal Agency, and Program Name: All major programs Federal Award Identification Number and Year: 2022 Finding Type – Material weakness over compliance Repeat Finding - No Criteria – Per 2 CFR 200.512 (a) (1), the audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Per 2 CFR 200.501 (b), a non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single audit conducted in accordance with § 200.514. Condition – The data collection form was not submitted within the required time as required by 2 CFR 200.512 for the year ended December 31, 2022. Context – The County’s single audit was not completed prior to the due date of data collection form. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause – The County’s Schedule of Federal Awards was not prepared in a timely manner. Effect – Data collection forms were not submitted on time. Recommendation – We recommend that the County develop a reliable system to close the financial records in a timely manner. View of Responsible Officials and Corrective Action Plan – The 2022 Single Audit was not completed within the required timeline primarily as a result of staff turnover and resource requirements surrounding the implementation of a new ERP system in 2023. New staff have been assigned to the preparation of the Schedule of Expenditures of Federal Awards (SEFA) beginning in 2023 and the new system went live in October 2023.
Assistance Listing Number, Federal Agency, and Program Name: All major programs Federal Award Identification Number and Year: 2022 Finding Type – Material weakness over compliance Repeat Finding - No Criteria – Per 2 CFR 200.512 (a) (1), the audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Per 2 CFR 200.501 (b), a non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single audit conducted in accordance with § 200.514. Condition – The data collection form was not submitted within the required time as required by 2 CFR 200.512 for the year ended December 31, 2022. Context – The County’s single audit was not completed prior to the due date of data collection form. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause – The County’s Schedule of Federal Awards was not prepared in a timely manner. Effect – Data collection forms were not submitted on time. Recommendation – We recommend that the County develop a reliable system to close the financial records in a timely manner. View of Responsible Officials and Corrective Action Plan – The 2022 Single Audit was not completed within the required timeline primarily as a result of staff turnover and resource requirements surrounding the implementation of a new ERP system in 2023. New staff have been assigned to the preparation of the Schedule of Expenditures of Federal Awards (SEFA) beginning in 2023 and the new system went live in October 2023.
Assistance Listing Number, Federal Agency, and Program Name: All major programs Federal Award Identification Number and Year: 2022 Finding Type – Material weakness over compliance Repeat Finding - No Criteria – Per 2 CFR 200.512 (a) (1), the audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Per 2 CFR 200.501 (b), a non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single audit conducted in accordance with § 200.514. Condition – The data collection form was not submitted within the required time as required by 2 CFR 200.512 for the year ended December 31, 2022. Context – The County’s single audit was not completed prior to the due date of data collection form. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause – The County’s Schedule of Federal Awards was not prepared in a timely manner. Effect – Data collection forms were not submitted on time. Recommendation – We recommend that the County develop a reliable system to close the financial records in a timely manner. View of Responsible Officials and Corrective Action Plan – The 2022 Single Audit was not completed within the required timeline primarily as a result of staff turnover and resource requirements surrounding the implementation of a new ERP system in 2023. New staff have been assigned to the preparation of the Schedule of Expenditures of Federal Awards (SEFA) beginning in 2023 and the new system went live in October 2023.
Assistance Listing Number, Federal Agency, and Program Name: All major programs Federal Award Identification Number and Year: 2022 Finding Type – Material weakness over compliance Repeat Finding - No Criteria – Per 2 CFR 200.512 (a) (1), the audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Per 2 CFR 200.501 (b), a non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single audit conducted in accordance with § 200.514. Condition – The data collection form was not submitted within the required time as required by 2 CFR 200.512 for the year ended December 31, 2022. Context – The County’s single audit was not completed prior to the due date of data collection form. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause – The County’s Schedule of Federal Awards was not prepared in a timely manner. Effect – Data collection forms were not submitted on time. Recommendation – We recommend that the County develop a reliable system to close the financial records in a timely manner. View of Responsible Officials and Corrective Action Plan – The 2022 Single Audit was not completed within the required timeline primarily as a result of staff turnover and resource requirements surrounding the implementation of a new ERP system in 2023. New staff have been assigned to the preparation of the Schedule of Expenditures of Federal Awards (SEFA) beginning in 2023 and the new system went live in October 2023.
Assistance Listing Number, Federal Agency, and Program Name: All major programs Federal Award Identification Number and Year: 2022 Finding Type – Material weakness over compliance Repeat Finding - No Criteria – Per 2 CFR 200.512 (a) (1), the audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Per 2 CFR 200.501 (b), a non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single audit conducted in accordance with § 200.514. Condition – The data collection form was not submitted within the required time as required by 2 CFR 200.512 for the year ended December 31, 2022. Context – The County’s single audit was not completed prior to the due date of data collection form. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause – The County’s Schedule of Federal Awards was not prepared in a timely manner. Effect – Data collection forms were not submitted on time. Recommendation – We recommend that the County develop a reliable system to close the financial records in a timely manner. View of Responsible Officials and Corrective Action Plan – The 2022 Single Audit was not completed within the required timeline primarily as a result of staff turnover and resource requirements surrounding the implementation of a new ERP system in 2023. New staff have been assigned to the preparation of the Schedule of Expenditures of Federal Awards (SEFA) beginning in 2023 and the new system went live in October 2023.
Assistance Listing Number, Federal Agency, and Program Name: All major programs Federal Award Identification Number and Year: 2022 Finding Type – Material weakness over compliance Repeat Finding - No Criteria – Per 2 CFR 200.512 (a) (1), the audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Per 2 CFR 200.501 (b), a non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single audit conducted in accordance with § 200.514. Condition – The data collection form was not submitted within the required time as required by 2 CFR 200.512 for the year ended December 31, 2022. Context – The County’s single audit was not completed prior to the due date of data collection form. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause – The County’s Schedule of Federal Awards was not prepared in a timely manner. Effect – Data collection forms were not submitted on time. Recommendation – We recommend that the County develop a reliable system to close the financial records in a timely manner. View of Responsible Officials and Corrective Action Plan – The 2022 Single Audit was not completed within the required timeline primarily as a result of staff turnover and resource requirements surrounding the implementation of a new ERP system in 2023. New staff have been assigned to the preparation of the Schedule of Expenditures of Federal Awards (SEFA) beginning in 2023 and the new system went live in October 2023.
Assistance Listing Number, Federal Agency, and Program Name: All major programs Federal Award Identification Number and Year: 2022 Finding Type – Material weakness over compliance Repeat Finding - No Criteria – Per 2 CFR 200.512 (a) (1), the audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Per 2 CFR 200.501 (b), a non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single audit conducted in accordance with § 200.514. Condition – The data collection form was not submitted within the required time as required by 2 CFR 200.512 for the year ended December 31, 2022. Context – The County’s single audit was not completed prior to the due date of data collection form. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause – The County’s Schedule of Federal Awards was not prepared in a timely manner. Effect – Data collection forms were not submitted on time. Recommendation – We recommend that the County develop a reliable system to close the financial records in a timely manner. View of Responsible Officials and Corrective Action Plan – The 2022 Single Audit was not completed within the required timeline primarily as a result of staff turnover and resource requirements surrounding the implementation of a new ERP system in 2023. New staff have been assigned to the preparation of the Schedule of Expenditures of Federal Awards (SEFA) beginning in 2023 and the new system went live in October 2023.
Assistance Listing Number, Federal Agency, and Program Name: All major programs Federal Award Identification Number and Year: 2022 Finding Type – Material weakness over compliance Repeat Finding - No Criteria – Per 2 CFR 200.512 (a) (1), the audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Per 2 CFR 200.501 (b), a non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single audit conducted in accordance with § 200.514. Condition – The data collection form was not submitted within the required time as required by 2 CFR 200.512 for the year ended December 31, 2022. Context – The County’s single audit was not completed prior to the due date of data collection form. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause – The County’s Schedule of Federal Awards was not prepared in a timely manner. Effect – Data collection forms were not submitted on time. Recommendation – We recommend that the County develop a reliable system to close the financial records in a timely manner. View of Responsible Officials and Corrective Action Plan – The 2022 Single Audit was not completed within the required timeline primarily as a result of staff turnover and resource requirements surrounding the implementation of a new ERP system in 2023. New staff have been assigned to the preparation of the Schedule of Expenditures of Federal Awards (SEFA) beginning in 2023 and the new system went live in October 2023.
Assistance Listing Number, Federal Agency, and Program Name: All major programs Federal Award Identification Number and Year: 2022 Finding Type – Material weakness over compliance Repeat Finding - No Criteria – Per 2 CFR 200.512 (a) (1), the audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Per 2 CFR 200.501 (b), a non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single audit conducted in accordance with § 200.514. Condition – The data collection form was not submitted within the required time as required by 2 CFR 200.512 for the year ended December 31, 2022. Context – The County’s single audit was not completed prior to the due date of data collection form. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause – The County’s Schedule of Federal Awards was not prepared in a timely manner. Effect – Data collection forms were not submitted on time. Recommendation – We recommend that the County develop a reliable system to close the financial records in a timely manner. View of Responsible Officials and Corrective Action Plan – The 2022 Single Audit was not completed within the required timeline primarily as a result of staff turnover and resource requirements surrounding the implementation of a new ERP system in 2023. New staff have been assigned to the preparation of the Schedule of Expenditures of Federal Awards (SEFA) beginning in 2023 and the new system went live in October 2023.
Assistance Listing Number, Federal Agency, and Program Name: All major programs Federal Award Identification Number and Year: 2022 Finding Type – Material weakness over compliance Repeat Finding - No Criteria – Per 2 CFR 200.512 (a) (1), the audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Per 2 CFR 200.501 (b), a non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single audit conducted in accordance with § 200.514. Condition – The data collection form was not submitted within the required time as required by 2 CFR 200.512 for the year ended December 31, 2022. Context – The County’s single audit was not completed prior to the due date of data collection form. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause – The County’s Schedule of Federal Awards was not prepared in a timely manner. Effect – Data collection forms were not submitted on time. Recommendation – We recommend that the County develop a reliable system to close the financial records in a timely manner. View of Responsible Officials and Corrective Action Plan – The 2022 Single Audit was not completed within the required timeline primarily as a result of staff turnover and resource requirements surrounding the implementation of a new ERP system in 2023. New staff have been assigned to the preparation of the Schedule of Expenditures of Federal Awards (SEFA) beginning in 2023 and the new system went live in October 2023.
Assistance Listing Number, Federal Agency, and Program Name: All major programs Federal Award Identification Number and Year: 2022 Finding Type – Material weakness over compliance Repeat Finding - No Criteria – Per 2 CFR 200.512 (a) (1), the audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Per 2 CFR 200.501 (b), a non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single audit conducted in accordance with § 200.514. Condition – The data collection form was not submitted within the required time as required by 2 CFR 200.512 for the year ended December 31, 2022. Context – The County’s single audit was not completed prior to the due date of data collection form. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause – The County’s Schedule of Federal Awards was not prepared in a timely manner. Effect – Data collection forms were not submitted on time. Recommendation – We recommend that the County develop a reliable system to close the financial records in a timely manner. View of Responsible Officials and Corrective Action Plan – The 2022 Single Audit was not completed within the required timeline primarily as a result of staff turnover and resource requirements surrounding the implementation of a new ERP system in 2023. New staff have been assigned to the preparation of the Schedule of Expenditures of Federal Awards (SEFA) beginning in 2023 and the new system went live in October 2023.
Assistance Listing Number, Federal Agency, and Program Name: All major programs Federal Award Identification Number and Year: 2022 Finding Type – Material weakness over compliance Repeat Finding - No Criteria – Per 2 CFR 200.512 (a) (1), the audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Per 2 CFR 200.501 (b), a non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single audit conducted in accordance with § 200.514. Condition – The data collection form was not submitted within the required time as required by 2 CFR 200.512 for the year ended December 31, 2022. Context – The County’s single audit was not completed prior to the due date of data collection form. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause – The County’s Schedule of Federal Awards was not prepared in a timely manner. Effect – Data collection forms were not submitted on time. Recommendation – We recommend that the County develop a reliable system to close the financial records in a timely manner. View of Responsible Officials and Corrective Action Plan – The 2022 Single Audit was not completed within the required timeline primarily as a result of staff turnover and resource requirements surrounding the implementation of a new ERP system in 2023. New staff have been assigned to the preparation of the Schedule of Expenditures of Federal Awards (SEFA) beginning in 2023 and the new system went live in October 2023.
Assistance Listing Number, Federal Agency, and Program Name: All major programs Federal Award Identification Number and Year: 2022 Finding Type – Material weakness over compliance Repeat Finding - No Criteria – Per 2 CFR 200.512 (a) (1), the audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Per 2 CFR 200.501 (b), a non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single audit conducted in accordance with § 200.514. Condition – The data collection form was not submitted within the required time as required by 2 CFR 200.512 for the year ended December 31, 2022. Context – The County’s single audit was not completed prior to the due date of data collection form. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause – The County’s Schedule of Federal Awards was not prepared in a timely manner. Effect – Data collection forms were not submitted on time. Recommendation – We recommend that the County develop a reliable system to close the financial records in a timely manner. View of Responsible Officials and Corrective Action Plan – The 2022 Single Audit was not completed within the required timeline primarily as a result of staff turnover and resource requirements surrounding the implementation of a new ERP system in 2023. New staff have been assigned to the preparation of the Schedule of Expenditures of Federal Awards (SEFA) beginning in 2023 and the new system went live in October 2023.
Assistance Listing Number, Federal Agency, and Program Name: All major programs Federal Award Identification Number and Year: 2022 Finding Type – Material weakness over compliance Repeat Finding - No Criteria – Per 2 CFR 200.512 (a) (1), the audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Per 2 CFR 200.501 (b), a non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single audit conducted in accordance with § 200.514. Condition – The data collection form was not submitted within the required time as required by 2 CFR 200.512 for the year ended December 31, 2022. Context – The County’s single audit was not completed prior to the due date of data collection form. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause – The County’s Schedule of Federal Awards was not prepared in a timely manner. Effect – Data collection forms were not submitted on time. Recommendation – We recommend that the County develop a reliable system to close the financial records in a timely manner. View of Responsible Officials and Corrective Action Plan – The 2022 Single Audit was not completed within the required timeline primarily as a result of staff turnover and resource requirements surrounding the implementation of a new ERP system in 2023. New staff have been assigned to the preparation of the Schedule of Expenditures of Federal Awards (SEFA) beginning in 2023 and the new system went live in October 2023.
Assistance Listing Number, Federal Agency, and Program Name: All major programs Federal Award Identification Number and Year: 2022 Finding Type – Material weakness over compliance Repeat Finding - No Criteria – Per 2 CFR 200.512 (a) (1), the audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Per 2 CFR 200.501 (b), a non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single audit conducted in accordance with § 200.514. Condition – The data collection form was not submitted within the required time as required by 2 CFR 200.512 for the year ended December 31, 2022. Context – The County’s single audit was not completed prior to the due date of data collection form. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause – The County’s Schedule of Federal Awards was not prepared in a timely manner. Effect – Data collection forms were not submitted on time. Recommendation – We recommend that the County develop a reliable system to close the financial records in a timely manner. View of Responsible Officials and Corrective Action Plan – The 2022 Single Audit was not completed within the required timeline primarily as a result of staff turnover and resource requirements surrounding the implementation of a new ERP system in 2023. New staff have been assigned to the preparation of the Schedule of Expenditures of Federal Awards (SEFA) beginning in 2023 and the new system went live in October 2023.
Assistance Listing Number, Federal Agency, and Program Name: All major programs Federal Award Identification Number and Year: 2022 Finding Type – Material weakness over compliance Repeat Finding - No Criteria – Per 2 CFR 200.512 (a) (1), the audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Per 2 CFR 200.501 (b), a non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single audit conducted in accordance with § 200.514. Condition – The data collection form was not submitted within the required time as required by 2 CFR 200.512 for the year ended December 31, 2022. Context – The County’s single audit was not completed prior to the due date of data collection form. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause – The County’s Schedule of Federal Awards was not prepared in a timely manner. Effect – Data collection forms were not submitted on time. Recommendation – We recommend that the County develop a reliable system to close the financial records in a timely manner. View of Responsible Officials and Corrective Action Plan – The 2022 Single Audit was not completed within the required timeline primarily as a result of staff turnover and resource requirements surrounding the implementation of a new ERP system in 2023. New staff have been assigned to the preparation of the Schedule of Expenditures of Federal Awards (SEFA) beginning in 2023 and the new system went live in October 2023.
Assistance Listing Number, Federal Agency, and Program Name: All major programs Federal Award Identification Number and Year: 2022 Finding Type – Material weakness over compliance Repeat Finding - No Criteria – Per 2 CFR 200.512 (a) (1), the audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Per 2 CFR 200.501 (b), a non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single audit conducted in accordance with § 200.514. Condition – The data collection form was not submitted within the required time as required by 2 CFR 200.512 for the year ended December 31, 2022. Context – The County’s single audit was not completed prior to the due date of data collection form. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause – The County’s Schedule of Federal Awards was not prepared in a timely manner. Effect – Data collection forms were not submitted on time. Recommendation – We recommend that the County develop a reliable system to close the financial records in a timely manner. View of Responsible Officials and Corrective Action Plan – The 2022 Single Audit was not completed within the required timeline primarily as a result of staff turnover and resource requirements surrounding the implementation of a new ERP system in 2023. New staff have been assigned to the preparation of the Schedule of Expenditures of Federal Awards (SEFA) beginning in 2023 and the new system went live in October 2023.
Assistance Listing Number, Federal Agency, and Program Name: All major programs Federal Award Identification Number and Year: 2022 Finding Type – Material weakness over compliance Repeat Finding - No Criteria – Per 2 CFR 200.512 (a) (1), the audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Per 2 CFR 200.501 (b), a non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single audit conducted in accordance with § 200.514. Condition – The data collection form was not submitted within the required time as required by 2 CFR 200.512 for the year ended December 31, 2022. Context – The County’s single audit was not completed prior to the due date of data collection form. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause – The County’s Schedule of Federal Awards was not prepared in a timely manner. Effect – Data collection forms were not submitted on time. Recommendation – We recommend that the County develop a reliable system to close the financial records in a timely manner. View of Responsible Officials and Corrective Action Plan – The 2022 Single Audit was not completed within the required timeline primarily as a result of staff turnover and resource requirements surrounding the implementation of a new ERP system in 2023. New staff have been assigned to the preparation of the Schedule of Expenditures of Federal Awards (SEFA) beginning in 2023 and the new system went live in October 2023.
Assistance Listing Number, Federal Agency, and Program Name: All major programs Federal Award Identification Number and Year: 2022 Finding Type – Material weakness over compliance Repeat Finding - No Criteria – Per 2 CFR 200.512 (a) (1), the audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Per 2 CFR 200.501 (b), a non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single audit conducted in accordance with § 200.514. Condition – The data collection form was not submitted within the required time as required by 2 CFR 200.512 for the year ended December 31, 2022. Context – The County’s single audit was not completed prior to the due date of data collection form. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause – The County’s Schedule of Federal Awards was not prepared in a timely manner. Effect – Data collection forms were not submitted on time. Recommendation – We recommend that the County develop a reliable system to close the financial records in a timely manner. View of Responsible Officials and Corrective Action Plan – The 2022 Single Audit was not completed within the required timeline primarily as a result of staff turnover and resource requirements surrounding the implementation of a new ERP system in 2023. New staff have been assigned to the preparation of the Schedule of Expenditures of Federal Awards (SEFA) beginning in 2023 and the new system went live in October 2023.
Assistance Listing Number, Federal Agency, and Program Name: All major programs Federal Award Identification Number and Year: 2022 Finding Type – Material weakness over compliance Repeat Finding - No Criteria – Per 2 CFR 200.512 (a) (1), the audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Per 2 CFR 200.501 (b), a non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single audit conducted in accordance with § 200.514. Condition – The data collection form was not submitted within the required time as required by 2 CFR 200.512 for the year ended December 31, 2022. Context – The County’s single audit was not completed prior to the due date of data collection form. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause – The County’s Schedule of Federal Awards was not prepared in a timely manner. Effect – Data collection forms were not submitted on time. Recommendation – We recommend that the County develop a reliable system to close the financial records in a timely manner. View of Responsible Officials and Corrective Action Plan – The 2022 Single Audit was not completed within the required timeline primarily as a result of staff turnover and resource requirements surrounding the implementation of a new ERP system in 2023. New staff have been assigned to the preparation of the Schedule of Expenditures of Federal Awards (SEFA) beginning in 2023 and the new system went live in October 2023.
Assistance Listing Number, Federal Agency, and Program Name: All major programs Federal Award Identification Number and Year: 2022 Finding Type – Material weakness over compliance Repeat Finding - No Criteria – Per 2 CFR 200.512 (a) (1), the audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Per 2 CFR 200.501 (b), a non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single audit conducted in accordance with § 200.514. Condition – The data collection form was not submitted within the required time as required by 2 CFR 200.512 for the year ended December 31, 2022. Context – The County’s single audit was not completed prior to the due date of data collection form. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause – The County’s Schedule of Federal Awards was not prepared in a timely manner. Effect – Data collection forms were not submitted on time. Recommendation – We recommend that the County develop a reliable system to close the financial records in a timely manner. View of Responsible Officials and Corrective Action Plan – The 2022 Single Audit was not completed within the required timeline primarily as a result of staff turnover and resource requirements surrounding the implementation of a new ERP system in 2023. New staff have been assigned to the preparation of the Schedule of Expenditures of Federal Awards (SEFA) beginning in 2023 and the new system went live in October 2023.
Assistance Listing Number, Federal Agency, and Program Name: All major programs Federal Award Identification Number and Year: 2022 Finding Type – Material weakness over compliance Repeat Finding - No Criteria – Per 2 CFR 200.512 (a) (1), the audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Per 2 CFR 200.501 (b), a non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single audit conducted in accordance with § 200.514. Condition – The data collection form was not submitted within the required time as required by 2 CFR 200.512 for the year ended December 31, 2022. Context – The County’s single audit was not completed prior to the due date of data collection form. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause – The County’s Schedule of Federal Awards was not prepared in a timely manner. Effect – Data collection forms were not submitted on time. Recommendation – We recommend that the County develop a reliable system to close the financial records in a timely manner. View of Responsible Officials and Corrective Action Plan – The 2022 Single Audit was not completed within the required timeline primarily as a result of staff turnover and resource requirements surrounding the implementation of a new ERP system in 2023. New staff have been assigned to the preparation of the Schedule of Expenditures of Federal Awards (SEFA) beginning in 2023 and the new system went live in October 2023.
Assistance Listing Number, Federal Agency, and Program Name: All major programs Federal Award Identification Number and Year: 2022 Finding Type – Material weakness over compliance Repeat Finding - No Criteria – Per 2 CFR 200.512 (a) (1), the audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Per 2 CFR 200.501 (b), a non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single audit conducted in accordance with § 200.514. Condition – The data collection form was not submitted within the required time as required by 2 CFR 200.512 for the year ended December 31, 2022. Context – The County’s single audit was not completed prior to the due date of data collection form. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause – The County’s Schedule of Federal Awards was not prepared in a timely manner. Effect – Data collection forms were not submitted on time. Recommendation – We recommend that the County develop a reliable system to close the financial records in a timely manner. View of Responsible Officials and Corrective Action Plan – The 2022 Single Audit was not completed within the required timeline primarily as a result of staff turnover and resource requirements surrounding the implementation of a new ERP system in 2023. New staff have been assigned to the preparation of the Schedule of Expenditures of Federal Awards (SEFA) beginning in 2023 and the new system went live in October 2023.
Assistance Listing Number, Federal Agency, and Program Name: All major programs Federal Award Identification Number and Year: 2022 Finding Type – Material weakness over compliance Repeat Finding - No Criteria – Per 2 CFR 200.512 (a) (1), the audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Per 2 CFR 200.501 (b), a non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single audit conducted in accordance with § 200.514. Condition – The data collection form was not submitted within the required time as required by 2 CFR 200.512 for the year ended December 31, 2022. Context – The County’s single audit was not completed prior to the due date of data collection form. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause – The County’s Schedule of Federal Awards was not prepared in a timely manner. Effect – Data collection forms were not submitted on time. Recommendation – We recommend that the County develop a reliable system to close the financial records in a timely manner. View of Responsible Officials and Corrective Action Plan – The 2022 Single Audit was not completed within the required timeline primarily as a result of staff turnover and resource requirements surrounding the implementation of a new ERP system in 2023. New staff have been assigned to the preparation of the Schedule of Expenditures of Federal Awards (SEFA) beginning in 2023 and the new system went live in October 2023.
Assistance Listing Number, Federal Agency, and Program Name: All major programs Federal Award Identification Number and Year: 2022 Finding Type – Material weakness over compliance Repeat Finding - No Criteria – Per 2 CFR 200.512 (a) (1), the audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Per 2 CFR 200.501 (b), a non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single audit conducted in accordance with § 200.514. Condition – The data collection form was not submitted within the required time as required by 2 CFR 200.512 for the year ended December 31, 2022. Context – The County’s single audit was not completed prior to the due date of data collection form. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause – The County’s Schedule of Federal Awards was not prepared in a timely manner. Effect – Data collection forms were not submitted on time. Recommendation – We recommend that the County develop a reliable system to close the financial records in a timely manner. View of Responsible Officials and Corrective Action Plan – The 2022 Single Audit was not completed within the required timeline primarily as a result of staff turnover and resource requirements surrounding the implementation of a new ERP system in 2023. New staff have been assigned to the preparation of the Schedule of Expenditures of Federal Awards (SEFA) beginning in 2023 and the new system went live in October 2023.
Criteria - A non-Federal entity that expends $750,000 or more in Federal awards during the year must have a single audit conducted in accordance with 2 CFR §200.514. Pursuant to 2 CFR §200.512, the audit must be completed and Form SF-SAC: Data Collection Form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditors’ report(s), or nine months after year end of the audit period. Condition - We noted that KMNH has not submitted the single audit reports required by the Uniform Guidance, including the Data Collection Form to the Federal Audit Clearinghouse for the year ended December 31, 2022, within the stipulated nine months after the end of the audit period. Cause - KMNH has not adhered to established Uniform Guidance terms and conditions regarding the submission dates of the single audit reports and Data Collection Form for the year ended December 31, 2022. Effect - KMNH is not in compliance with the Uniform Guidance terms and conditions regarding the submission dates of the single audit report and Data Collection Form for the year ended December 31, 2022. Identification of a Repeat Finding - This finding was reported as a federal award finding in the immediate previous audit as Finding No. 2021-004. Recommendation - We again recommend that KMNH incorporate internal controls to ensure compliance with the Uniform Guidance with respect to the submission deadline of single audit reports and the Data Collection Form. Views of Responsible Officials and Planned Corrective Action - KMNH agrees with the finding and recommendation and have updated internal controls to monitor audit submissions to the Federal Audit Clearinghouse.
Criteria - A non-Federal entity that expends $750,000 or more in Federal awards during the year must have a single audit conducted in accordance with 2 CFR §200.514. Pursuant to 2 CFR §200.512, the audit must be completed and Form SF-SAC: Data Collection Form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditors’ report(s), or nine months after year end of the audit period. Condition - We noted that KMNH has not submitted the single audit reports required by the Uniform Guidance, including the Data Collection Form to the Federal Audit Clearinghouse for the year ended December 31, 2022, within the stipulated nine months after the end of the audit period. Cause - KMNH has not adhered to established Uniform Guidance terms and conditions regarding the submission dates of the single audit reports and Data Collection Form for the year ended December 31, 2022. Effect - KMNH is not in compliance with the Uniform Guidance terms and conditions regarding the submission dates of the single audit report and Data Collection Form for the year ended December 31, 2022. Identification of a Repeat Finding - This finding was reported as a federal award finding in the immediate previous audit as Finding No. 2021-004. Recommendation - We again recommend that KMNH incorporate internal controls to ensure compliance with the Uniform Guidance with respect to the submission deadline of single audit reports and the Data Collection Form. Views of Responsible Officials and Planned Corrective Action - KMNH agrees with the finding and recommendation and have updated internal controls to monitor audit submissions to the Federal Audit Clearinghouse.
Criteria - A non-Federal entity that expends $750,000 or more in Federal awards during the year must have a single audit conducted in accordance with 2 CFR §200.514. Pursuant to 2 CFR §200.512, the audit must be completed and Form SF-SAC: Data Collection Form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditors’ report(s), or nine months after year end of the audit period. Condition - We noted that KMNH has not submitted the single audit reports required by the Uniform Guidance, including the Data Collection Form to the Federal Audit Clearinghouse for the year ended December 31, 2022, within the stipulated nine months after the end of the audit period. Cause - KMNH has not adhered to established Uniform Guidance terms and conditions regarding the submission dates of the single audit reports and Data Collection Form for the year ended December 31, 2022. Effect - KMNH is not in compliance with the Uniform Guidance terms and conditions regarding the submission dates of the single audit report and Data Collection Form for the year ended December 31, 2022. Identification of a Repeat Finding - This finding was reported as a federal award finding in the immediate previous audit as Finding No. 2021-004. Recommendation - We again recommend that KMNH incorporate internal controls to ensure compliance with the Uniform Guidance with respect to the submission deadline of single audit reports and the Data Collection Form. Views of Responsible Officials and Planned Corrective Action - KMNH agrees with the finding and recommendation and have updated internal controls to monitor audit submissions to the Federal Audit Clearinghouse.
Criteria: 2 CFR Part 200 in general and 2 CFR section 200.332 require non-Federal entities to establish and maintain effective internal controls over Federal awards, including the requirements for allowable costs, cost principles, reporting, and suspension and debarment. The related compliance requirements are set in 2 CFR Part 200 sections 200.514(c), 200.212, 200.318(h), 180.300 and subpart E; 48 CFR section 52.209-6; 31 CFR section 19.300; sections 602 and 603 of the Social Security Act as added by section 9901 of the American Rescue Plan Act of 2021, Pub. L. No. 117-2 as codified at 42 USC 802 and 803 and 31 CFR Part 35, federal awarding agency regulations, and the terms and conditions of the award. Condition: Controls related to calculation and reporting of lost revenue were not effective and the amount calculated as base year revenue was incorrectly reported. Controls related to reporting of other grant expenditures were not effective and certain amounts were missing from the financial reports. Controls related to ensuring contractors were not suspended, debarred, or otherwise excluded pursuant to 31 CFR section 19.300 were not documented in a manner that is reperformable. Cause: Base year calculation of revenue was performed using interim financial information and was not reconciled to final audited reports. Base year calculation of revenue was not clearly documented. Subsequent year revenue calculations were performed by a consultant who was not engaged to review the base year calculation. Controls over such calculations were not effective. Review of financial reports was not sufficient to ensure all grant expenditures were reported. Suspension and debarment controls were not evidenced with clear documentation; checklists are maintained but were not completed in all cases. Effect: Calculation of lost revenue was incorrectly reported. Expenditures related to the provision of government services related to such lost revenue did not exceed the actual lost revenue. Certain other grant expenditures were erroneously excluded from the financial reports. Procurement of contractors risks including those who were suspended or debarred; however none such were identified. Recommendation: We recommend that the City ensure that all controls for grants be documented in written procedures which should include the name or title of the positions responsible for each control (preparation, review, reconciliation, etc.) and that the performance of the controls be documented in a clear, reperformable manner including the name and date of each responsible individual and which specific control they performed over compliance for the grant.
Criteria: 2 CFR 200.514 of the uniform guidance requires entities to have internal controls in place to monitor that expenditures are only for allowable activities and that services charged to the federal award are allowable per the applicable cost principles. In addition, a fundamental concept in a good system of internal controls is the segregation of duties; segregating access, custody, and authorization of transactions. These controls aid in mitigating risk in monitoring. Condition and context: Through inquiry and internal control testing, it was noted that the employees outside of the HR department have access to employee information within the system. This includes potential access to pay rates and other protected information inside the system. Payroll costs represent the majority of federal award expenditures for the medical center. Questioned costs: none. Cause/Effect: No questioned costs or errors were identified during testing of the award expenditures, however, the lack of separation of duties related to access to employee information and pay rates within the system increases the risk of unallowable costs being charged to the federal program. Repeat finding: yes; refer to finding 2021-003. Recommendation: With the implementation of a new system, we recommend that user access for management and staff be limited to their assigned duties. Until such systems are finalized and placed in service, periodic reviews of employee information and transactions should be performed. Any and all unauthorized changes should be documented and evidence should be retained in a secure location. View of responsible officials and corrective action plan: Management should fully integrate new system (Microsoft Dynamics-GP) by the end of this fiscal year. The new system will have the capability to limit user access according to assigned duties.
Finding Type - Material weakness relative to timely reporting of the schedule of expenditures of federal awards ("SEFA") and associated data collection form on reporting for single audits. Criteria - Per 2 CFR 200.512 (a) (1 ), the audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Per 2 CFR 200.501 (b), a non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single audit conducted in accordance with§ 200.514. Condition - The data collection form was not submitted within the required time as required by 2 CFR 200.512. Context - In fiscal year 2022, the Organization had $1,631,922 in expenditures under various federal awards to report on the Schedule of Expenditures of Federal Awards ("SEFA"). The Organization did not have the single audit completed within the Uniform Guidance required timeframe. Cause/Effect - The Organization's controls were not adequate to ensure compliance with federal statutes, regulations, and Uniform Guidance requirements. Recommendation - We recommend the Organization strengthen internal controls and evaluate or monitor compliance with federal statutes, regulations, and the terms and conditions of their awards. In addition, we recommend the Organization ensures that SEFA is reviewed prior to providing it to the auditors. Finally, the Organization should consider incorporating the SEFA preparation within their checklist for the monthly closeout process.
Criteria: 2 CFR Part 200 in general and 2 CFR section 200.332 require non-Federal entities to establish and maintain effective internal controls over Federal awards, including the requirements for allowable costs, cost principles, reporting, and suspension and debarment. The related compliance requirements are set in 2 CFR Part 200 sections 200.514(c), 200.212, 200.318(h), 180.300 and subpart E; 48 CFR section 52.209-6; 31 CFR section 19.300; sections 602 and 603 of the Social Security Act as added by section 9901 of the American Rescue Plan Act of 2021, Pub. L. No. 117-2 as codified at 42 USC 802 and 803 and 31 CFR Part 35, federal awarding agency regulations, and the terms and conditions of the award. Condition: Controls related to calculation and reporting of lost revenue were not effective and the amount calculated as base year revenue was incorrectly reported. Controls related to reporting of other grant expenditures were not effective and certain amounts were missing from the financial reports. Controls related to ensuring contractors were not suspended, debarred, or otherwise excluded pursuant to 31 CFR section 19.300 were not documented in a manner that is reperformable. Cause: Base year calculation of revenue was performed using interim financial information and was not reconciled to final audited reports. Base year calculation of revenue was not clearly documented. Subsequent year revenue calculations were performed by a consultant who was not engaged to review the base year calculation. Controls over such calculations were not effective. Review of financial reports was not sufficient to ensure all grant expenditures were reported. Suspension and debarment controls were not evidenced with clear documentation; checklists are maintained but were not completed in all cases. Effect: Calculation of lost revenue was incorrectly reported. Expenditures related to the provision of government services related to such lost revenue did not exceed the actual lost revenue. Certain other grant expenditures were erroneously excluded from the financial reports. Procurement of contractors risks including those who were suspended or debarred; however none such were identified. Recommendation: We recommend that the City ensure that all controls for grants be documented in written procedures which should include the name or title of the positions responsible for each control (preparation, review, reconciliation, etc.) and that the performance of the controls be documented in a clear, reperformable manner including the name and date of each responsible individual and which specific control they performed over compliance for the grant.
Criteria: 2 CFR 200.514 of the uniform guidance requires entities to have internal controls in place to monitor that expenditures are only for allowable activities and that services charged to the federal award are allowable per the applicable cost principles. In addition, a fundamental concept in a good system of internal controls is the segregation of duties; segregating access, custody, and authorization of transactions. These controls aid in mitigating risk in monitoring. Condition and context: Through inquiry and internal control testing, it was noted that the employees outside of the HR department have access to employee information within the system. This includes potential access to pay rates and other protected information inside the system. Payroll costs represent the majority of federal award expenditures for the medical center. Questioned costs: none. Cause/Effect: No questioned costs or errors were identified during testing of the award expenditures, however, the lack of separation of duties related to access to employee information and pay rates within the system increases the risk of unallowable costs being charged to the federal program. Repeat finding: yes; refer to finding 2021-003. Recommendation: With the implementation of a new system, we recommend that user access for management and staff be limited to their assigned duties. Until such systems are finalized and placed in service, periodic reviews of employee information and transactions should be performed. Any and all unauthorized changes should be documented and evidence should be retained in a secure location. View of responsible officials and corrective action plan: Management should fully integrate new system (Microsoft Dynamics-GP) by the end of this fiscal year. The new system will have the capability to limit user access according to assigned duties.
Finding Type - Material weakness relative to timely reporting of the schedule of expenditures of federal awards ("SEFA") and associated data collection form on reporting for single audits. Criteria - Per 2 CFR 200.512 (a) (1 ), the audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Per 2 CFR 200.501 (b), a non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single audit conducted in accordance with§ 200.514. Condition - The data collection form was not submitted within the required time as required by 2 CFR 200.512. Context - In fiscal year 2022, the Organization had $1,631,922 in expenditures under various federal awards to report on the Schedule of Expenditures of Federal Awards ("SEFA"). The Organization did not have the single audit completed within the Uniform Guidance required timeframe. Cause/Effect - The Organization's controls were not adequate to ensure compliance with federal statutes, regulations, and Uniform Guidance requirements. Recommendation - We recommend the Organization strengthen internal controls and evaluate or monitor compliance with federal statutes, regulations, and the terms and conditions of their awards. In addition, we recommend the Organization ensures that SEFA is reviewed prior to providing it to the auditors. Finally, the Organization should consider incorporating the SEFA preparation within their checklist for the monthly closeout process.
2022-030 The University of Washington did not have adequate internal controls over and did not comply with federal requirements to ensure subrecipients of the Global AIDS program received required single or program-specific audits, and that it followed up on findings and issued management decisions. Assistance Listing Number and Title: 93.067 Global AIDS 93.067 COVID-19 Global AIDS Federal Grantor Name: U.S. Department of Health and Human Services Federal Award/Contract Number: NU2GGH001430; NU2GGH001968; NU2GGH002038; NU2GGH002116; NU2GGH002242; NUGGH002360; NU2GGH002157; NU2GGH002298; NU2GGH002374 Pass-through Entity Name: None Pass-through Award/Contract Number: None Applicable Compliance Component: Subrecipient Monitoring Known Questioned Cost Amount: None Background The Global AIDS program is a federal initiative focused on treating and preventing the transmission of HIV/AIDS around the world. The program is authorized by Sections 307 and 317(k)(2) of the Public Health Service Act, the U.S. Leadership Against HIV/AIDS, Tuberculosis, and Malaria Acts of 2003 and 2008, and the U.S. President?s Emergency Plan for AIDS Relief. Since it was established in 2003, the federal government has invested more than $100 billion in the global HIV/AIDS response, providing testing and treatment for millions of people, preventing transmission among affected communities, and supporting numerous countries to achieve HIV epidemic control. The program distributes funding through public and private sector partnerships to reach the populations most vulnerable to HIV/AIDS epidemics. The University of Washington administers this grant for the state through its International Training and Education Center for Health (I-TECH). I-TECH is a center in the University?s Department of Global Health operated by more than 2,000 staff in offices located in Africa, Asia, the Caribbean, Eastern Europe and the United States. In fiscal year 2022, the University spent more than $66 million in federal program funds, about $44 million of which it passed through to subrecipients. Federal regulations require the University to monitor its subrecipients? activities. This includes verifying that its subrecipients that spend $750,000 or more in federal awards during a fiscal year obtain a single or program-specific audit. For the Global AIDS program, the Centers for Disease Control and Prevention requires foreign subrecipients to submit their audits directly to the federal government and pass-through entity within 30 days after receiving the auditor?s report or nine months after the end of the subrecipient?s audit period, whichever is earlier. Additionally, for the awards it passes onto its subrecipients, the University must follow up and ensure the subrecipients take timely and appropriate corrective action on all deficiencies identified through audits. When a subrecipient receives an audit finding for a University-funded program, federal law requires the University to issue a management decision to the subrecipient within six months of the audit report?s acceptance by the federal government. The management decision must clearly state whether the audit finding is sustained, the reason for the decision, and the actions the subrecipient is expected to take, such as repaying unallowable costs or making financial adjustments. These requirements help ensure subrecipients use federal program funds for authorized purposes and within the provisions of contracts or grant agreements. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Description of Condition The University did not have adequate internal controls over and did not comply with federal requirements to ensure subrecipients of the Global AIDS program received required single or program-specific audits, and that it appropriately followed up on findings and issued management decisions. We found the University did not have adequate internal controls in place to verify whether: ? Subrecipients received required audits, if necessary, and appropriate remedies were taken if audits were not filed ? Management decisions were required to be issued for subrecipients who required a single or program-specific audit We used a nonstatistical sampling method to randomly select and examine seven out of a total population of 21 subrecipients. We found the University did not adequately monitor one subrecipient (14 percent) to ensure it received a required single or program-specific audit. We consider these internal control deficiencies to be a material weakness, which led to material noncompliance. This issue was not reported as a finding in the prior audit. Cause of Condition Staff in the University?s Office of Sponsored Programs (OSP) used a spreadsheet to track subrecipient certifications and responses, and reviewed annual certifications from the subrecipient to monitor its audit status. However, OSP did not correctly interpret the subrecipient?s response and, therefore, did not require it to provide documentation of a single or program-specific audit. Additionally, management did not review the subrecipient?s federal assistance expenditures to detect that it required an audit and, therefore, also failed to adequately follow up to ensure any reported findings were resolved with appropriate corrective action, if required. Effect of Condition Without establishing adequate internal controls, the University cannot ensure all subrecipients that required a single or program-specific audit received one. Furthermore, the University cannot ensure it is following up on subrecipient audit findings and communicating required management decisions to subrecipients. By failing to ensure subrecipients establish corrective actions and management monitors them for effectiveness where required, the University cannot determine whether subrecipients have sufficiently corrected issues identified in audit findings. Recommendations We recommend the University: ? Follow policies and procedures to ensure subrecipients receive required single or program-specific audits ? Establish and follow effective internal controls to ensure it reviews audit reports for its subrecipients and issues written management decisions, as required ? Ensure subrecipients develop and perform acceptable corrective actions to adequately address all audit recommendations ? Follow up with the subrecipient to ensure the required audit reports are received and reviewed to determine if the subrecipient is required to take corrective action to address audit recommendations ? Issue a written management decision for all applicable audit findings, if necessary University?s Response The University of Washington has established internal controls to carry out a risk assessment per Uniform Guidance, 2 CFR ? 200.332, Requirements for pass-through entities, and our UW Grants Information Memorandum (GIM) 8. This involves using various factors to assess risk. Part of our process to obtain the information needed from each subrecipient is through a certification process. The certification was obtained from the subrecipient, along with additional documentation from the subrecipient, such as an audited financial statement. We made a risk assessment using our standard risk criteria. We did misinterpret the response provided from the subrecipient regarding whether it expended $750,000 or more in federal awards during a fiscal year in order to obtain a single or program-specific audit from this subrecipient. While this was not obtained and reviewed, a risk assessment using our standard criteria was performed with the subrecipient rated as a medium risk, and subject to monitoring throughout the project, per GIM 8. The monitoring at the program level occurred during the period in question. We will be improving our required communications with subrecipients to have clear questions and responses regarding whether the subrecipient expended $750,000 or more in federal awards during the fiscal year in order to obtain a single or program-specific audit, follow up with the subrecipient to ensure the required audit reports are received and reviewed to determine if the subrecipient is required to take corrective action to address audit recommendations, and issue a written management decision for all applicable audit findings, if necessary. Auditor?s Remarks We thank the University for its cooperation and assistance during the audit. Whether the University performed a risk assessment for the subrecipient is not being questioned. The University did not adequately monitor the subrecipient to ensure it detected whether the subrecipient was required to receive a single audit, or program-specific audit in accordance with 2 CFR ?200.332(f). There is no other mechanism for the Federal government to monitor subrecipients of the University and, because a single audit of the subrecipient was not performed, neither the federal grantor nor the University had reasonable assurance of the subrecipient?s compliance with federal award requirements. We reaffirm our finding and will follow up on the status of the University?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 CFR Part 200, Uniform Guidance, establishes the following applicable requirements: Section 200.332 Requirements for pass-through entities, states in part: All pass-through entities must: (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. (3) Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by ? 200.521. (4) The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient?s cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section ? 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. (f) Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set for the in ?200.501 Audit requirements. Section 200.339 Remedies for noncompliance, states: If a non-Federal entity fails to comply with the U.S. Constitution, Federal statutes, regulations or the terms and conditions of a Federal award, the Federal awarding agency or pass-through entity may impose additional conditions, as described in ? 200.208. If the Federal awarding agency or pass-through entity determines that noncompliance cannot be remedied by imposing additional conditions, the Federal awarding agency or pass-through entity may take one or more of the following actions, as appropriate in the circumstances: (a) Temporarily withhold cash payments pending correction of the deficiency by the non-Federal entity or more severe enforcement action by the Federal awarding agency or pass-through entity. (b) Disallow (that is, deny both use of funds and any applicable matching credit for) all or part of the cost of the activity or action not in compliance. (c) Wholly or partly suspend or terminate the Federal award. (d) Initiate suspension or debarment proceedings as authorized under 2 CFR part 180 and Federal awarding agency regulations (or in the case of a pass-through entity, recommend such a proceeding be initiated by a Federal awarding agency). (e) Withhold further Federal awards for the project or program. (f) Take other remedies that may be legally available. Section 200.501 Audit requirements, states in part: (a) Audit required. A non-Federal entity that expends $750,000 or more during the non-Federal entity?s fiscal year in Federal awards must have a single or program-specific audit conducted for that year in accordance with the provisions of this part. (b) Single audit. A non-Federal entity that expends $750,000 or more during the non-Federal entity?s fiscal year in Federal awards must have a single audit conducted in accordance with ? 200.514 except when it elects to have a program-specific audit conducted in accordance with paragraph (c) of this section. Section 200.521 Management decision, states in part: (a) General. The management decision must clearly state whether or not the audit finding is sustained, the reasons for the decision, and the expected auditee action to repay disallowed costs, make financial adjustments, or take other action. If the auditee has not completed corrective action, a timetable for follow-up should be given. Prior to issuing the management decision, the Federal agency or pass-through entity may request additional information or documentation from the auditee, including a request for auditor assurance related to the documentation, as a way of mitigating disallowed costs. The management decision should describe any appeal process available to the auditee. While not required, the Federal agency or pass-through entity may also issue a management decision on findings relating to the financial statements which are required to be reported in accordance with GAGAS. (c) Pass-through entity. As provided in ? 200.332(d), the pass-through entity must be responsible for issuing a management decision for audit findings that relate to Federal awards it makes to subrecipients. (d) Time requirements. The Federal awarding agency or pass-through entity responsible for issuing a management decision must do so within six months of acceptance of the audit report by the FAC. The auditee must initiate and proceed with corrective action as rapidly as possible and corrective action should begin no later than upon receipt of the audit report. (e) Reference numbers. Management decisions must include the reference numbers the auditor assigned to each audit finding in accordance with ? 200.516(c). The University of Washington?s Policies, Procedures and Guidance (UW Research), GIM 8 ? Subrecipient Monitoring, states in part: Background Additionally, per the Federal Uniform Guidance, UW must evaluate each subrecipients? risk of noncompliance with federal regulations, include specific terms and conditions in the subaward as necessary, and monitor the activities of the subrecipient through various mechanisms. These mechanisms include: Training and technical assistance to subrecipients, on-site reviews, review of audit results, increased reporting requirements and enforcement action, if necessary. University Policy UW reviews each subrecipient entity according to an entity level comprehensive risk assessment prior to the issuance of a subaward. This risk assessment includes an entity level review of their fiscal systems, past audit activity, and if required, financial statements of the entity as well as the project specific activity proposed and that the required compliance approvals are obtained. When necessary, UW imposes limitations and requirements on the subrecipient through subaward terms and conditions per Federal Uniform Guidance, Section 200.521, prior to the issuance or renewal of a subaward. UW?s subrecipient monitoring requirements are comprised, at a minimum, of the following: ? Completion of the UW?s entity level comprehensive risk assessment (Certs & Reps, Annual Audit Certification) Subrecipient Monitoring ? Entity Level Entity level monitoring consists of a combination of the following: ? Initial Subrecipient Certification Form completion and assurance by subrecipient?s authorized official ? Annual audit assurance through an annual audit certification form ? Maintenance of a subrecipient profile list, which includes information on the entity?s past audit information and certifications ? Risk assessment carried out at each annual renewal of a subaward
2022-030 The University of Washington did not have adequate internal controls over and did not comply with federal requirements to ensure subrecipients of the Global AIDS program received required single or program-specific audits, and that it followed up on findings and issued management decisions. Assistance Listing Number and Title: 93.067 Global AIDS 93.067 COVID-19 Global AIDS Federal Grantor Name: U.S. Department of Health and Human Services Federal Award/Contract Number: NU2GGH001430; NU2GGH001968; NU2GGH002038; NU2GGH002116; NU2GGH002242; NUGGH002360; NU2GGH002157; NU2GGH002298; NU2GGH002374 Pass-through Entity Name: None Pass-through Award/Contract Number: None Applicable Compliance Component: Subrecipient Monitoring Known Questioned Cost Amount: None Background The Global AIDS program is a federal initiative focused on treating and preventing the transmission of HIV/AIDS around the world. The program is authorized by Sections 307 and 317(k)(2) of the Public Health Service Act, the U.S. Leadership Against HIV/AIDS, Tuberculosis, and Malaria Acts of 2003 and 2008, and the U.S. President?s Emergency Plan for AIDS Relief. Since it was established in 2003, the federal government has invested more than $100 billion in the global HIV/AIDS response, providing testing and treatment for millions of people, preventing transmission among affected communities, and supporting numerous countries to achieve HIV epidemic control. The program distributes funding through public and private sector partnerships to reach the populations most vulnerable to HIV/AIDS epidemics. The University of Washington administers this grant for the state through its International Training and Education Center for Health (I-TECH). I-TECH is a center in the University?s Department of Global Health operated by more than 2,000 staff in offices located in Africa, Asia, the Caribbean, Eastern Europe and the United States. In fiscal year 2022, the University spent more than $66 million in federal program funds, about $44 million of which it passed through to subrecipients. Federal regulations require the University to monitor its subrecipients? activities. This includes verifying that its subrecipients that spend $750,000 or more in federal awards during a fiscal year obtain a single or program-specific audit. For the Global AIDS program, the Centers for Disease Control and Prevention requires foreign subrecipients to submit their audits directly to the federal government and pass-through entity within 30 days after receiving the auditor?s report or nine months after the end of the subrecipient?s audit period, whichever is earlier. Additionally, for the awards it passes onto its subrecipients, the University must follow up and ensure the subrecipients take timely and appropriate corrective action on all deficiencies identified through audits. When a subrecipient receives an audit finding for a University-funded program, federal law requires the University to issue a management decision to the subrecipient within six months of the audit report?s acceptance by the federal government. The management decision must clearly state whether the audit finding is sustained, the reason for the decision, and the actions the subrecipient is expected to take, such as repaying unallowable costs or making financial adjustments. These requirements help ensure subrecipients use federal program funds for authorized purposes and within the provisions of contracts or grant agreements. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Description of Condition The University did not have adequate internal controls over and did not comply with federal requirements to ensure subrecipients of the Global AIDS program received required single or program-specific audits, and that it appropriately followed up on findings and issued management decisions. We found the University did not have adequate internal controls in place to verify whether: ? Subrecipients received required audits, if necessary, and appropriate remedies were taken if audits were not filed ? Management decisions were required to be issued for subrecipients who required a single or program-specific audit We used a nonstatistical sampling method to randomly select and examine seven out of a total population of 21 subrecipients. We found the University did not adequately monitor one subrecipient (14 percent) to ensure it received a required single or program-specific audit. We consider these internal control deficiencies to be a material weakness, which led to material noncompliance. This issue was not reported as a finding in the prior audit. Cause of Condition Staff in the University?s Office of Sponsored Programs (OSP) used a spreadsheet to track subrecipient certifications and responses, and reviewed annual certifications from the subrecipient to monitor its audit status. However, OSP did not correctly interpret the subrecipient?s response and, therefore, did not require it to provide documentation of a single or program-specific audit. Additionally, management did not review the subrecipient?s federal assistance expenditures to detect that it required an audit and, therefore, also failed to adequately follow up to ensure any reported findings were resolved with appropriate corrective action, if required. Effect of Condition Without establishing adequate internal controls, the University cannot ensure all subrecipients that required a single or program-specific audit received one. Furthermore, the University cannot ensure it is following up on subrecipient audit findings and communicating required management decisions to subrecipients. By failing to ensure subrecipients establish corrective actions and management monitors them for effectiveness where required, the University cannot determine whether subrecipients have sufficiently corrected issues identified in audit findings. Recommendations We recommend the University: ? Follow policies and procedures to ensure subrecipients receive required single or program-specific audits ? Establish and follow effective internal controls to ensure it reviews audit reports for its subrecipients and issues written management decisions, as required ? Ensure subrecipients develop and perform acceptable corrective actions to adequately address all audit recommendations ? Follow up with the subrecipient to ensure the required audit reports are received and reviewed to determine if the subrecipient is required to take corrective action to address audit recommendations ? Issue a written management decision for all applicable audit findings, if necessary University?s Response The University of Washington has established internal controls to carry out a risk assessment per Uniform Guidance, 2 CFR ? 200.332, Requirements for pass-through entities, and our UW Grants Information Memorandum (GIM) 8. This involves using various factors to assess risk. Part of our process to obtain the information needed from each subrecipient is through a certification process. The certification was obtained from the subrecipient, along with additional documentation from the subrecipient, such as an audited financial statement. We made a risk assessment using our standard risk criteria. We did misinterpret the response provided from the subrecipient regarding whether it expended $750,000 or more in federal awards during a fiscal year in order to obtain a single or program-specific audit from this subrecipient. While this was not obtained and reviewed, a risk assessment using our standard criteria was performed with the subrecipient rated as a medium risk, and subject to monitoring throughout the project, per GIM 8. The monitoring at the program level occurred during the period in question. We will be improving our required communications with subrecipients to have clear questions and responses regarding whether the subrecipient expended $750,000 or more in federal awards during the fiscal year in order to obtain a single or program-specific audit, follow up with the subrecipient to ensure the required audit reports are received and reviewed to determine if the subrecipient is required to take corrective action to address audit recommendations, and issue a written management decision for all applicable audit findings, if necessary. Auditor?s Remarks We thank the University for its cooperation and assistance during the audit. Whether the University performed a risk assessment for the subrecipient is not being questioned. The University did not adequately monitor the subrecipient to ensure it detected whether the subrecipient was required to receive a single audit, or program-specific audit in accordance with 2 CFR ?200.332(f). There is no other mechanism for the Federal government to monitor subrecipients of the University and, because a single audit of the subrecipient was not performed, neither the federal grantor nor the University had reasonable assurance of the subrecipient?s compliance with federal award requirements. We reaffirm our finding and will follow up on the status of the University?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 CFR Part 200, Uniform Guidance, establishes the following applicable requirements: Section 200.332 Requirements for pass-through entities, states in part: All pass-through entities must: (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. (3) Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by ? 200.521. (4) The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient?s cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section ? 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. (f) Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set for the in ?200.501 Audit requirements. Section 200.339 Remedies for noncompliance, states: If a non-Federal entity fails to comply with the U.S. Constitution, Federal statutes, regulations or the terms and conditions of a Federal award, the Federal awarding agency or pass-through entity may impose additional conditions, as described in ? 200.208. If the Federal awarding agency or pass-through entity determines that noncompliance cannot be remedied by imposing additional conditions, the Federal awarding agency or pass-through entity may take one or more of the following actions, as appropriate in the circumstances: (a) Temporarily withhold cash payments pending correction of the deficiency by the non-Federal entity or more severe enforcement action by the Federal awarding agency or pass-through entity. (b) Disallow (that is, deny both use of funds and any applicable matching credit for) all or part of the cost of the activity or action not in compliance. (c) Wholly or partly suspend or terminate the Federal award. (d) Initiate suspension or debarment proceedings as authorized under 2 CFR part 180 and Federal awarding agency regulations (or in the case of a pass-through entity, recommend such a proceeding be initiated by a Federal awarding agency). (e) Withhold further Federal awards for the project or program. (f) Take other remedies that may be legally available. Section 200.501 Audit requirements, states in part: (a) Audit required. A non-Federal entity that expends $750,000 or more during the non-Federal entity?s fiscal year in Federal awards must have a single or program-specific audit conducted for that year in accordance with the provisions of this part. (b) Single audit. A non-Federal entity that expends $750,000 or more during the non-Federal entity?s fiscal year in Federal awards must have a single audit conducted in accordance with ? 200.514 except when it elects to have a program-specific audit conducted in accordance with paragraph (c) of this section. Section 200.521 Management decision, states in part: (a) General. The management decision must clearly state whether or not the audit finding is sustained, the reasons for the decision, and the expected auditee action to repay disallowed costs, make financial adjustments, or take other action. If the auditee has not completed corrective action, a timetable for follow-up should be given. Prior to issuing the management decision, the Federal agency or pass-through entity may request additional information or documentation from the auditee, including a request for auditor assurance related to the documentation, as a way of mitigating disallowed costs. The management decision should describe any appeal process available to the auditee. While not required, the Federal agency or pass-through entity may also issue a management decision on findings relating to the financial statements which are required to be reported in accordance with GAGAS. (c) Pass-through entity. As provided in ? 200.332(d), the pass-through entity must be responsible for issuing a management decision for audit findings that relate to Federal awards it makes to subrecipients. (d) Time requirements. The Federal awarding agency or pass-through entity responsible for issuing a management decision must do so within six months of acceptance of the audit report by the FAC. The auditee must initiate and proceed with corrective action as rapidly as possible and corrective action should begin no later than upon receipt of the audit report. (e) Reference numbers. Management decisions must include the reference numbers the auditor assigned to each audit finding in accordance with ? 200.516(c). The University of Washington?s Policies, Procedures and Guidance (UW Research), GIM 8 ? Subrecipient Monitoring, states in part: Background Additionally, per the Federal Uniform Guidance, UW must evaluate each subrecipients? risk of noncompliance with federal regulations, include specific terms and conditions in the subaward as necessary, and monitor the activities of the subrecipient through various mechanisms. These mechanisms include: Training and technical assistance to subrecipients, on-site reviews, review of audit results, increased reporting requirements and enforcement action, if necessary. University Policy UW reviews each subrecipient entity according to an entity level comprehensive risk assessment prior to the issuance of a subaward. This risk assessment includes an entity level review of their fiscal systems, past audit activity, and if required, financial statements of the entity as well as the project specific activity proposed and that the required compliance approvals are obtained. When necessary, UW imposes limitations and requirements on the subrecipient through subaward terms and conditions per Federal Uniform Guidance, Section 200.521, prior to the issuance or renewal of a subaward. UW?s subrecipient monitoring requirements are comprised, at a minimum, of the following: ? Completion of the UW?s entity level comprehensive risk assessment (Certs & Reps, Annual Audit Certification) Subrecipient Monitoring ? Entity Level Entity level monitoring consists of a combination of the following: ? Initial Subrecipient Certification Form completion and assurance by subrecipient?s authorized official ? Annual audit assurance through an annual audit certification form ? Maintenance of a subrecipient profile list, which includes information on the entity?s past audit information and certifications ? Risk assessment carried out at each annual renewal of a subaward
2022-030 The University of Washington did not have adequate internal controls over and did not comply with federal requirements to ensure subrecipients of the Global AIDS program received required single or program-specific audits, and that it followed up on findings and issued management decisions. Assistance Listing Number and Title: 93.067 Global AIDS 93.067 COVID-19 Global AIDS Federal Grantor Name: U.S. Department of Health and Human Services Federal Award/Contract Number: NU2GGH001430; NU2GGH001968; NU2GGH002038; NU2GGH002116; NU2GGH002242; NUGGH002360; NU2GGH002157; NU2GGH002298; NU2GGH002374 Pass-through Entity Name: None Pass-through Award/Contract Number: None Applicable Compliance Component: Subrecipient Monitoring Known Questioned Cost Amount: None Background The Global AIDS program is a federal initiative focused on treating and preventing the transmission of HIV/AIDS around the world. The program is authorized by Sections 307 and 317(k)(2) of the Public Health Service Act, the U.S. Leadership Against HIV/AIDS, Tuberculosis, and Malaria Acts of 2003 and 2008, and the U.S. President?s Emergency Plan for AIDS Relief. Since it was established in 2003, the federal government has invested more than $100 billion in the global HIV/AIDS response, providing testing and treatment for millions of people, preventing transmission among affected communities, and supporting numerous countries to achieve HIV epidemic control. The program distributes funding through public and private sector partnerships to reach the populations most vulnerable to HIV/AIDS epidemics. The University of Washington administers this grant for the state through its International Training and Education Center for Health (I-TECH). I-TECH is a center in the University?s Department of Global Health operated by more than 2,000 staff in offices located in Africa, Asia, the Caribbean, Eastern Europe and the United States. In fiscal year 2022, the University spent more than $66 million in federal program funds, about $44 million of which it passed through to subrecipients. Federal regulations require the University to monitor its subrecipients? activities. This includes verifying that its subrecipients that spend $750,000 or more in federal awards during a fiscal year obtain a single or program-specific audit. For the Global AIDS program, the Centers for Disease Control and Prevention requires foreign subrecipients to submit their audits directly to the federal government and pass-through entity within 30 days after receiving the auditor?s report or nine months after the end of the subrecipient?s audit period, whichever is earlier. Additionally, for the awards it passes onto its subrecipients, the University must follow up and ensure the subrecipients take timely and appropriate corrective action on all deficiencies identified through audits. When a subrecipient receives an audit finding for a University-funded program, federal law requires the University to issue a management decision to the subrecipient within six months of the audit report?s acceptance by the federal government. The management decision must clearly state whether the audit finding is sustained, the reason for the decision, and the actions the subrecipient is expected to take, such as repaying unallowable costs or making financial adjustments. These requirements help ensure subrecipients use federal program funds for authorized purposes and within the provisions of contracts or grant agreements. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Description of Condition The University did not have adequate internal controls over and did not comply with federal requirements to ensure subrecipients of the Global AIDS program received required single or program-specific audits, and that it appropriately followed up on findings and issued management decisions. We found the University did not have adequate internal controls in place to verify whether: ? Subrecipients received required audits, if necessary, and appropriate remedies were taken if audits were not filed ? Management decisions were required to be issued for subrecipients who required a single or program-specific audit We used a nonstatistical sampling method to randomly select and examine seven out of a total population of 21 subrecipients. We found the University did not adequately monitor one subrecipient (14 percent) to ensure it received a required single or program-specific audit. We consider these internal control deficiencies to be a material weakness, which led to material noncompliance. This issue was not reported as a finding in the prior audit. Cause of Condition Staff in the University?s Office of Sponsored Programs (OSP) used a spreadsheet to track subrecipient certifications and responses, and reviewed annual certifications from the subrecipient to monitor its audit status. However, OSP did not correctly interpret the subrecipient?s response and, therefore, did not require it to provide documentation of a single or program-specific audit. Additionally, management did not review the subrecipient?s federal assistance expenditures to detect that it required an audit and, therefore, also failed to adequately follow up to ensure any reported findings were resolved with appropriate corrective action, if required. Effect of Condition Without establishing adequate internal controls, the University cannot ensure all subrecipients that required a single or program-specific audit received one. Furthermore, the University cannot ensure it is following up on subrecipient audit findings and communicating required management decisions to subrecipients. By failing to ensure subrecipients establish corrective actions and management monitors them for effectiveness where required, the University cannot determine whether subrecipients have sufficiently corrected issues identified in audit findings. Recommendations We recommend the University: ? Follow policies and procedures to ensure subrecipients receive required single or program-specific audits ? Establish and follow effective internal controls to ensure it reviews audit reports for its subrecipients and issues written management decisions, as required ? Ensure subrecipients develop and perform acceptable corrective actions to adequately address all audit recommendations ? Follow up with the subrecipient to ensure the required audit reports are received and reviewed to determine if the subrecipient is required to take corrective action to address audit recommendations ? Issue a written management decision for all applicable audit findings, if necessary University?s Response The University of Washington has established internal controls to carry out a risk assessment per Uniform Guidance, 2 CFR ? 200.332, Requirements for pass-through entities, and our UW Grants Information Memorandum (GIM) 8. This involves using various factors to assess risk. Part of our process to obtain the information needed from each subrecipient is through a certification process. The certification was obtained from the subrecipient, along with additional documentation from the subrecipient, such as an audited financial statement. We made a risk assessment using our standard risk criteria. We did misinterpret the response provided from the subrecipient regarding whether it expended $750,000 or more in federal awards during a fiscal year in order to obtain a single or program-specific audit from this subrecipient. While this was not obtained and reviewed, a risk assessment using our standard criteria was performed with the subrecipient rated as a medium risk, and subject to monitoring throughout the project, per GIM 8. The monitoring at the program level occurred during the period in question. We will be improving our required communications with subrecipients to have clear questions and responses regarding whether the subrecipient expended $750,000 or more in federal awards during the fiscal year in order to obtain a single or program-specific audit, follow up with the subrecipient to ensure the required audit reports are received and reviewed to determine if the subrecipient is required to take corrective action to address audit recommendations, and issue a written management decision for all applicable audit findings, if necessary. Auditor?s Remarks We thank the University for its cooperation and assistance during the audit. Whether the University performed a risk assessment for the subrecipient is not being questioned. The University did not adequately monitor the subrecipient to ensure it detected whether the subrecipient was required to receive a single audit, or program-specific audit in accordance with 2 CFR ?200.332(f). There is no other mechanism for the Federal government to monitor subrecipients of the University and, because a single audit of the subrecipient was not performed, neither the federal grantor nor the University had reasonable assurance of the subrecipient?s compliance with federal award requirements. We reaffirm our finding and will follow up on the status of the University?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 CFR Part 200, Uniform Guidance, establishes the following applicable requirements: Section 200.332 Requirements for pass-through entities, states in part: All pass-through entities must: (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. (3) Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by ? 200.521. (4) The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient?s cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section ? 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. (f) Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set for the in ?200.501 Audit requirements. Section 200.339 Remedies for noncompliance, states: If a non-Federal entity fails to comply with the U.S. Constitution, Federal statutes, regulations or the terms and conditions of a Federal award, the Federal awarding agency or pass-through entity may impose additional conditions, as described in ? 200.208. If the Federal awarding agency or pass-through entity determines that noncompliance cannot be remedied by imposing additional conditions, the Federal awarding agency or pass-through entity may take one or more of the following actions, as appropriate in the circumstances: (a) Temporarily withhold cash payments pending correction of the deficiency by the non-Federal entity or more severe enforcement action by the Federal awarding agency or pass-through entity. (b) Disallow (that is, deny both use of funds and any applicable matching credit for) all or part of the cost of the activity or action not in compliance. (c) Wholly or partly suspend or terminate the Federal award. (d) Initiate suspension or debarment proceedings as authorized under 2 CFR part 180 and Federal awarding agency regulations (or in the case of a pass-through entity, recommend such a proceeding be initiated by a Federal awarding agency). (e) Withhold further Federal awards for the project or program. (f) Take other remedies that may be legally available. Section 200.501 Audit requirements, states in part: (a) Audit required. A non-Federal entity that expends $750,000 or more during the non-Federal entity?s fiscal year in Federal awards must have a single or program-specific audit conducted for that year in accordance with the provisions of this part. (b) Single audit. A non-Federal entity that expends $750,000 or more during the non-Federal entity?s fiscal year in Federal awards must have a single audit conducted in accordance with ? 200.514 except when it elects to have a program-specific audit conducted in accordance with paragraph (c) of this section. Section 200.521 Management decision, states in part: (a) General. The management decision must clearly state whether or not the audit finding is sustained, the reasons for the decision, and the expected auditee action to repay disallowed costs, make financial adjustments, or take other action. If the auditee has not completed corrective action, a timetable for follow-up should be given. Prior to issuing the management decision, the Federal agency or pass-through entity may request additional information or documentation from the auditee, including a request for auditor assurance related to the documentation, as a way of mitigating disallowed costs. The management decision should describe any appeal process available to the auditee. While not required, the Federal agency or pass-through entity may also issue a management decision on findings relating to the financial statements which are required to be reported in accordance with GAGAS. (c) Pass-through entity. As provided in ? 200.332(d), the pass-through entity must be responsible for issuing a management decision for audit findings that relate to Federal awards it makes to subrecipients. (d) Time requirements. The Federal awarding agency or pass-through entity responsible for issuing a management decision must do so within six months of acceptance of the audit report by the FAC. The auditee must initiate and proceed with corrective action as rapidly as possible and corrective action should begin no later than upon receipt of the audit report. (e) Reference numbers. Management decisions must include the reference numbers the auditor assigned to each audit finding in accordance with ? 200.516(c). The University of Washington?s Policies, Procedures and Guidance (UW Research), GIM 8 ? Subrecipient Monitoring, states in part: Background Additionally, per the Federal Uniform Guidance, UW must evaluate each subrecipients? risk of noncompliance with federal regulations, include specific terms and conditions in the subaward as necessary, and monitor the activities of the subrecipient through various mechanisms. These mechanisms include: Training and technical assistance to subrecipients, on-site reviews, review of audit results, increased reporting requirements and enforcement action, if necessary. University Policy UW reviews each subrecipient entity according to an entity level comprehensive risk assessment prior to the issuance of a subaward. This risk assessment includes an entity level review of their fiscal systems, past audit activity, and if required, financial statements of the entity as well as the project specific activity proposed and that the required compliance approvals are obtained. When necessary, UW imposes limitations and requirements on the subrecipient through subaward terms and conditions per Federal Uniform Guidance, Section 200.521, prior to the issuance or renewal of a subaward. UW?s subrecipient monitoring requirements are comprised, at a minimum, of the following: ? Completion of the UW?s entity level comprehensive risk assessment (Certs & Reps, Annual Audit Certification) Subrecipient Monitoring ? Entity Level Entity level monitoring consists of a combination of the following: ? Initial Subrecipient Certification Form completion and assurance by subrecipient?s authorized official ? Annual audit assurance through an annual audit certification form ? Maintenance of a subrecipient profile list, which includes information on the entity?s past audit information and certifications ? Risk assessment carried out at each annual renewal of a subaward
2022-030 The University of Washington did not have adequate internal controls over and did not comply with federal requirements to ensure subrecipients of the Global AIDS program received required single or program-specific audits, and that it followed up on findings and issued management decisions. Assistance Listing Number and Title: 93.067 Global AIDS 93.067 COVID-19 Global AIDS Federal Grantor Name: U.S. Department of Health and Human Services Federal Award/Contract Number: NU2GGH001430; NU2GGH001968; NU2GGH002038; NU2GGH002116; NU2GGH002242; NUGGH002360; NU2GGH002157; NU2GGH002298; NU2GGH002374 Pass-through Entity Name: None Pass-through Award/Contract Number: None Applicable Compliance Component: Subrecipient Monitoring Known Questioned Cost Amount: None Background The Global AIDS program is a federal initiative focused on treating and preventing the transmission of HIV/AIDS around the world. The program is authorized by Sections 307 and 317(k)(2) of the Public Health Service Act, the U.S. Leadership Against HIV/AIDS, Tuberculosis, and Malaria Acts of 2003 and 2008, and the U.S. President?s Emergency Plan for AIDS Relief. Since it was established in 2003, the federal government has invested more than $100 billion in the global HIV/AIDS response, providing testing and treatment for millions of people, preventing transmission among affected communities, and supporting numerous countries to achieve HIV epidemic control. The program distributes funding through public and private sector partnerships to reach the populations most vulnerable to HIV/AIDS epidemics. The University of Washington administers this grant for the state through its International Training and Education Center for Health (I-TECH). I-TECH is a center in the University?s Department of Global Health operated by more than 2,000 staff in offices located in Africa, Asia, the Caribbean, Eastern Europe and the United States. In fiscal year 2022, the University spent more than $66 million in federal program funds, about $44 million of which it passed through to subrecipients. Federal regulations require the University to monitor its subrecipients? activities. This includes verifying that its subrecipients that spend $750,000 or more in federal awards during a fiscal year obtain a single or program-specific audit. For the Global AIDS program, the Centers for Disease Control and Prevention requires foreign subrecipients to submit their audits directly to the federal government and pass-through entity within 30 days after receiving the auditor?s report or nine months after the end of the subrecipient?s audit period, whichever is earlier. Additionally, for the awards it passes onto its subrecipients, the University must follow up and ensure the subrecipients take timely and appropriate corrective action on all deficiencies identified through audits. When a subrecipient receives an audit finding for a University-funded program, federal law requires the University to issue a management decision to the subrecipient within six months of the audit report?s acceptance by the federal government. The management decision must clearly state whether the audit finding is sustained, the reason for the decision, and the actions the subrecipient is expected to take, such as repaying unallowable costs or making financial adjustments. These requirements help ensure subrecipients use federal program funds for authorized purposes and within the provisions of contracts or grant agreements. Federal regulations require recipients to establish and follow internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Description of Condition The University did not have adequate internal controls over and did not comply with federal requirements to ensure subrecipients of the Global AIDS program received required single or program-specific audits, and that it appropriately followed up on findings and issued management decisions. We found the University did not have adequate internal controls in place to verify whether: ? Subrecipients received required audits, if necessary, and appropriate remedies were taken if audits were not filed ? Management decisions were required to be issued for subrecipients who required a single or program-specific audit We used a nonstatistical sampling method to randomly select and examine seven out of a total population of 21 subrecipients. We found the University did not adequately monitor one subrecipient (14 percent) to ensure it received a required single or program-specific audit. We consider these internal control deficiencies to be a material weakness, which led to material noncompliance. This issue was not reported as a finding in the prior audit. Cause of Condition Staff in the University?s Office of Sponsored Programs (OSP) used a spreadsheet to track subrecipient certifications and responses, and reviewed annual certifications from the subrecipient to monitor its audit status. However, OSP did not correctly interpret the subrecipient?s response and, therefore, did not require it to provide documentation of a single or program-specific audit. Additionally, management did not review the subrecipient?s federal assistance expenditures to detect that it required an audit and, therefore, also failed to adequately follow up to ensure any reported findings were resolved with appropriate corrective action, if required. Effect of Condition Without establishing adequate internal controls, the University cannot ensure all subrecipients that required a single or program-specific audit received one. Furthermore, the University cannot ensure it is following up on subrecipient audit findings and communicating required management decisions to subrecipients. By failing to ensure subrecipients establish corrective actions and management monitors them for effectiveness where required, the University cannot determine whether subrecipients have sufficiently corrected issues identified in audit findings. Recommendations We recommend the University: ? Follow policies and procedures to ensure subrecipients receive required single or program-specific audits ? Establish and follow effective internal controls to ensure it reviews audit reports for its subrecipients and issues written management decisions, as required ? Ensure subrecipients develop and perform acceptable corrective actions to adequately address all audit recommendations ? Follow up with the subrecipient to ensure the required audit reports are received and reviewed to determine if the subrecipient is required to take corrective action to address audit recommendations ? Issue a written management decision for all applicable audit findings, if necessary University?s Response The University of Washington has established internal controls to carry out a risk assessment per Uniform Guidance, 2 CFR ? 200.332, Requirements for pass-through entities, and our UW Grants Information Memorandum (GIM) 8. This involves using various factors to assess risk. Part of our process to obtain the information needed from each subrecipient is through a certification process. The certification was obtained from the subrecipient, along with additional documentation from the subrecipient, such as an audited financial statement. We made a risk assessment using our standard risk criteria. We did misinterpret the response provided from the subrecipient regarding whether it expended $750,000 or more in federal awards during a fiscal year in order to obtain a single or program-specific audit from this subrecipient. While this was not obtained and reviewed, a risk assessment using our standard criteria was performed with the subrecipient rated as a medium risk, and subject to monitoring throughout the project, per GIM 8. The monitoring at the program level occurred during the period in question. We will be improving our required communications with subrecipients to have clear questions and responses regarding whether the subrecipient expended $750,000 or more in federal awards during the fiscal year in order to obtain a single or program-specific audit, follow up with the subrecipient to ensure the required audit reports are received and reviewed to determine if the subrecipient is required to take corrective action to address audit recommendations, and issue a written management decision for all applicable audit findings, if necessary. Auditor?s Remarks We thank the University for its cooperation and assistance during the audit. Whether the University performed a risk assessment for the subrecipient is not being questioned. The University did not adequately monitor the subrecipient to ensure it detected whether the subrecipient was required to receive a single audit, or program-specific audit in accordance with 2 CFR ?200.332(f). There is no other mechanism for the Federal government to monitor subrecipients of the University and, because a single audit of the subrecipient was not performed, neither the federal grantor nor the University had reasonable assurance of the subrecipient?s compliance with federal award requirements. We reaffirm our finding and will follow up on the status of the University?s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 CFR Part 200, Uniform Guidance, establishes the following applicable requirements: Section 200.332 Requirements for pass-through entities, states in part: All pass-through entities must: (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. (3) Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by ? 200.521. (4) The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient?s cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section ? 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. (f) Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set for the in ?200.501 Audit requirements. Section 200.339 Remedies for noncompliance, states: If a non-Federal entity fails to comply with the U.S. Constitution, Federal statutes, regulations or the terms and conditions of a Federal award, the Federal awarding agency or pass-through entity may impose additional conditions, as described in ? 200.208. If the Federal awarding agency or pass-through entity determines that noncompliance cannot be remedied by imposing additional conditions, the Federal awarding agency or pass-through entity may take one or more of the following actions, as appropriate in the circumstances: (a) Temporarily withhold cash payments pending correction of the deficiency by the non-Federal entity or more severe enforcement action by the Federal awarding agency or pass-through entity. (b) Disallow (that is, deny both use of funds and any applicable matching credit for) all or part of the cost of the activity or action not in compliance. (c) Wholly or partly suspend or terminate the Federal award. (d) Initiate suspension or debarment proceedings as authorized under 2 CFR part 180 and Federal awarding agency regulations (or in the case of a pass-through entity, recommend such a proceeding be initiated by a Federal awarding agency). (e) Withhold further Federal awards for the project or program. (f) Take other remedies that may be legally available. Section 200.501 Audit requirements, states in part: (a) Audit required. A non-Federal entity that expends $750,000 or more during the non-Federal entity?s fiscal year in Federal awards must have a single or program-specific audit conducted for that year in accordance with the provisions of this part. (b) Single audit. A non-Federal entity that expends $750,000 or more during the non-Federal entity?s fiscal year in Federal awards must have a single audit conducted in accordance with ? 200.514 except when it elects to have a program-specific audit conducted in accordance with paragraph (c) of this section. Section 200.521 Management decision, states in part: (a) General. The management decision must clearly state whether or not the audit finding is sustained, the reasons for the decision, and the expected auditee action to repay disallowed costs, make financial adjustments, or take other action. If the auditee has not completed corrective action, a timetable for follow-up should be given. Prior to issuing the management decision, the Federal agency or pass-through entity may request additional information or documentation from the auditee, including a request for auditor assurance related to the documentation, as a way of mitigating disallowed costs. The management decision should describe any appeal process available to the auditee. While not required, the Federal agency or pass-through entity may also issue a management decision on findings relating to the financial statements which are required to be reported in accordance with GAGAS. (c) Pass-through entity. As provided in ? 200.332(d), the pass-through entity must be responsible for issuing a management decision for audit findings that relate to Federal awards it makes to subrecipients. (d) Time requirements. The Federal awarding agency or pass-through entity responsible for issuing a management decision must do so within six months of acceptance of the audit report by the FAC. The auditee must initiate and proceed with corrective action as rapidly as possible and corrective action should begin no later than upon receipt of the audit report. (e) Reference numbers. Management decisions must include the reference numbers the auditor assigned to each audit finding in accordance with ? 200.516(c). The University of Washington?s Policies, Procedures and Guidance (UW Research), GIM 8 ? Subrecipient Monitoring, states in part: Background Additionally, per the Federal Uniform Guidance, UW must evaluate each subrecipients? risk of noncompliance with federal regulations, include specific terms and conditions in the subaward as necessary, and monitor the activities of the subrecipient through various mechanisms. These mechanisms include: Training and technical assistance to subrecipients, on-site reviews, review of audit results, increased reporting requirements and enforcement action, if necessary. University Policy UW reviews each subrecipient entity according to an entity level comprehensive risk assessment prior to the issuance of a subaward. This risk assessment includes an entity level review of their fiscal systems, past audit activity, and if required, financial statements of the entity as well as the project specific activity proposed and that the required compliance approvals are obtained. When necessary, UW imposes limitations and requirements on the subrecipient through subaward terms and conditions per Federal Uniform Guidance, Section 200.521, prior to the issuance or renewal of a subaward. UW?s subrecipient monitoring requirements are comprised, at a minimum, of the following: ? Completion of the UW?s entity level comprehensive risk assessment (Certs & Reps, Annual Audit Certification) Subrecipient Monitoring ? Entity Level Entity level monitoring consists of a combination of the following: ? Initial Subrecipient Certification Form completion and assurance by subrecipient?s authorized official ? Annual audit assurance through an annual audit certification form ? Maintenance of a subrecipient profile list, which includes information on the entity?s past audit information and certifications ? Risk assessment carried out at each annual renewal of a subaward