2022-001 Eligibility Housing Voucher Cluster Continuum of Care Program AL No. 14.267 Other Matter required to be reported under 2 CFR 200.516(a) Condition: Out of an approximate population of 43,000 tenants in the Housing Voucher Cluster programs, 44 tenant files were tested and the following deficiencies were noted: ? 8 files did not receive an annual recertification within the required compliance timeframe. ? 4 of which were completed within 13 months ? 2 files did not include adequate income support. Out of an approximate population of 3,500 tenants in the Continuum of Care Program, 44 tenant files were tested and the following deficiencies were noted: ? 12 files did not receive an annual recertification within the required compliance timeframe. ? 6 of which were completed within 13 months ? 2 files did not include adequate income support. ? 2 files were missing 9886 forms effective for the fiscal year. Criteria: The Authority?s Administrative Plan, 24 CFR 982.516, 24 CFR 578 and the Authority?s Continuum of Care Policies require internal controls to be in place to ensure proper procedures are being followed in compliance with HUD requirements regarding timely, complete and accurate tenant files. Context: The auditor randomly selected 44 tenant files out of each program?s population, which we consider to be a statistically valid sample size. The auditor reviewed the tenant files and support to ensure that proper procedures are being followed and that the Authority is in compliance with HUD requirements regarding timely, complete, and accurate tenant files. Cause: The Authority experienced staffing and operational challenges during the onset of the COVID-19 pandemic. Those challenges have continued although the CARES Act Wavers expired on December 31, 2021. Additionally, a significant portion of the population being served are transient in nature and obtaining timely and accurate information is challenging. Effect: The Authority is not in compliance with HUD requirements regarding eligibility which could result in the incorrect amount of rental assistance provided. Questioned Costs: None. Auditor Recommendations: The Authority should consider reevaluating their established procedures and controls currently in place to ensure full compliance in regards to eligibility and the timeliness of recertifications. The Authority needs to correct the deficiencies noted in the tested files and consider the impact to the rest of the population of tenant files that were not selected as part of the auditor?s sample. Management Response: See Corrective Action Plan.
2022-001 Eligibility Housing Voucher Cluster Continuum of Care Program AL No. 14.267 Other Matter required to be reported under 2 CFR 200.516(a) Condition: Out of an approximate population of 43,000 tenants in the Housing Voucher Cluster programs, 44 tenant files were tested and the following deficiencies were noted: ? 8 files did not receive an annual recertification within the required compliance timeframe. ? 4 of which were completed within 13 months ? 2 files did not include adequate income support. Out of an approximate population of 3,500 tenants in the Continuum of Care Program, 44 tenant files were tested and the following deficiencies were noted: ? 12 files did not receive an annual recertification within the required compliance timeframe. ? 6 of which were completed within 13 months ? 2 files did not include adequate income support. ? 2 files were missing 9886 forms effective for the fiscal year. Criteria: The Authority?s Administrative Plan, 24 CFR 982.516, 24 CFR 578 and the Authority?s Continuum of Care Policies require internal controls to be in place to ensure proper procedures are being followed in compliance with HUD requirements regarding timely, complete and accurate tenant files. Context: The auditor randomly selected 44 tenant files out of each program?s population, which we consider to be a statistically valid sample size. The auditor reviewed the tenant files and support to ensure that proper procedures are being followed and that the Authority is in compliance with HUD requirements regarding timely, complete, and accurate tenant files. Cause: The Authority experienced staffing and operational challenges during the onset of the COVID-19 pandemic. Those challenges have continued although the CARES Act Wavers expired on December 31, 2021. Additionally, a significant portion of the population being served are transient in nature and obtaining timely and accurate information is challenging. Effect: The Authority is not in compliance with HUD requirements regarding eligibility which could result in the incorrect amount of rental assistance provided. Questioned Costs: None. Auditor Recommendations: The Authority should consider reevaluating their established procedures and controls currently in place to ensure full compliance in regards to eligibility and the timeliness of recertifications. The Authority needs to correct the deficiencies noted in the tested files and consider the impact to the rest of the population of tenant files that were not selected as part of the auditor?s sample. Management Response: See Corrective Action Plan.
2022-001 Eligibility Housing Voucher Cluster Continuum of Care Program AL No. 14.267 Other Matter required to be reported under 2 CFR 200.516(a) Condition: Out of an approximate population of 43,000 tenants in the Housing Voucher Cluster programs, 44 tenant files were tested and the following deficiencies were noted: ? 8 files did not receive an annual recertification within the required compliance timeframe. ? 4 of which were completed within 13 months ? 2 files did not include adequate income support. Out of an approximate population of 3,500 tenants in the Continuum of Care Program, 44 tenant files were tested and the following deficiencies were noted: ? 12 files did not receive an annual recertification within the required compliance timeframe. ? 6 of which were completed within 13 months ? 2 files did not include adequate income support. ? 2 files were missing 9886 forms effective for the fiscal year. Criteria: The Authority?s Administrative Plan, 24 CFR 982.516, 24 CFR 578 and the Authority?s Continuum of Care Policies require internal controls to be in place to ensure proper procedures are being followed in compliance with HUD requirements regarding timely, complete and accurate tenant files. Context: The auditor randomly selected 44 tenant files out of each program?s population, which we consider to be a statistically valid sample size. The auditor reviewed the tenant files and support to ensure that proper procedures are being followed and that the Authority is in compliance with HUD requirements regarding timely, complete, and accurate tenant files. Cause: The Authority experienced staffing and operational challenges during the onset of the COVID-19 pandemic. Those challenges have continued although the CARES Act Wavers expired on December 31, 2021. Additionally, a significant portion of the population being served are transient in nature and obtaining timely and accurate information is challenging. Effect: The Authority is not in compliance with HUD requirements regarding eligibility which could result in the incorrect amount of rental assistance provided. Questioned Costs: None. Auditor Recommendations: The Authority should consider reevaluating their established procedures and controls currently in place to ensure full compliance in regards to eligibility and the timeliness of recertifications. The Authority needs to correct the deficiencies noted in the tested files and consider the impact to the rest of the population of tenant files that were not selected as part of the auditor?s sample. Management Response: See Corrective Action Plan.
2022-001 Eligibility Housing Voucher Cluster Continuum of Care Program AL No. 14.267 Other Matter required to be reported under 2 CFR 200.516(a) Condition: Out of an approximate population of 43,000 tenants in the Housing Voucher Cluster programs, 44 tenant files were tested and the following deficiencies were noted: ? 8 files did not receive an annual recertification within the required compliance timeframe. ? 4 of which were completed within 13 months ? 2 files did not include adequate income support. Out of an approximate population of 3,500 tenants in the Continuum of Care Program, 44 tenant files were tested and the following deficiencies were noted: ? 12 files did not receive an annual recertification within the required compliance timeframe. ? 6 of which were completed within 13 months ? 2 files did not include adequate income support. ? 2 files were missing 9886 forms effective for the fiscal year. Criteria: The Authority?s Administrative Plan, 24 CFR 982.516, 24 CFR 578 and the Authority?s Continuum of Care Policies require internal controls to be in place to ensure proper procedures are being followed in compliance with HUD requirements regarding timely, complete and accurate tenant files. Context: The auditor randomly selected 44 tenant files out of each program?s population, which we consider to be a statistically valid sample size. The auditor reviewed the tenant files and support to ensure that proper procedures are being followed and that the Authority is in compliance with HUD requirements regarding timely, complete, and accurate tenant files. Cause: The Authority experienced staffing and operational challenges during the onset of the COVID-19 pandemic. Those challenges have continued although the CARES Act Wavers expired on December 31, 2021. Additionally, a significant portion of the population being served are transient in nature and obtaining timely and accurate information is challenging. Effect: The Authority is not in compliance with HUD requirements regarding eligibility which could result in the incorrect amount of rental assistance provided. Questioned Costs: None. Auditor Recommendations: The Authority should consider reevaluating their established procedures and controls currently in place to ensure full compliance in regards to eligibility and the timeliness of recertifications. The Authority needs to correct the deficiencies noted in the tested files and consider the impact to the rest of the population of tenant files that were not selected as part of the auditor?s sample. Management Response: See Corrective Action Plan.
2022-003 Financial Impropriety Information on Federal Program(s) U.S. Department of State Name of Program: Program to End Modern Slavery Assistance Listing Number: 19.019 Grant Award Number: S-SJTIP-17-CA-1018/S-SJTIP-18-CA-1014/ S-SJTIP-18-CA-3035 Grant Award Period: October 1, 2017 through June 30, 2022, October 1, 2018 through December 31, 2022, October 1, 2021 to September 30, 2024 Criteria - §200.516(a) Audit findings(6) requires known or suspected fraud be reported by the auditors. Condition - During the year ended December 31, 2022, the Fund received an e-mail from one of its subrecipients stating that they received a whistleblower complaint about an alleged financial impropriety that occurred within their country office. The subrecipient conducted an internal audit, which confirmed in December 2022 some of the allegations including receipt of per diem for trips not attended and use of an office vehicle and fuel for personal use. In February 2023, the subrecipient also contracted with a consultant to perform a forensic audit of the suspected inappropriate procurement and corruption activities at their Uganda Country office for the period from January 1, 2019 through December 31, 2022. The forensic report highlighted certain amounts that were misappropriated from the PEMS 2 grant for the year ended December 31, 2022. The Fund did not suffer any financial loss, since the Fund subtracted the misappropriated amount from the final disbursement to the subrecipient. In addition, in accordance with 2CFR 200.113, the Fund disclosed the financial impropriety incident to the Office of the Inspector General (OIG) for the Department of State and the cognizant Grants Officer was aware of substantiated misappropriation that impacted funding sub-awarded by the Fund to the subrecipient under the PEMS 2 grant. Cause - Individuals at the subrecipient organization committed inappropriate procurement and corruption activities. Effect - These conditions could result in unallowable expenses being charged to U.S. Government awards if the whistle blower complaint and subsequent investigation did not identify the financial impropriety. Questioned Costs - There are no questioned costs since the Fund subtracted the misappropriated amount from the final disbursement to the subrecipient. Context - This matter was identified through a whistleblower complaint at the subrecipient organization during the year ended December 31, 2022. Repeat Finding - This is not a repeat finding. Recommendation - The Fund should continue to monitor and assess the control environment in which its subrecipients operate. The Fund should also ensure a detailed risk assessment of all subrecipients is regularly performed and reviewed. It should also assess whether future funding be provided to the subrecipient. View of Responsible Officials - Management agrees with the Federal award finding identified in the audit. The Fund’s response to this finding is described in the accompanying management’s corrective action plan.
2022-003 Financial Impropriety Information on Federal Program(s) U.S. Department of State Name of Program: Program to End Modern Slavery Assistance Listing Number: 19.019 Grant Award Number: S-SJTIP-17-CA-1018/S-SJTIP-18-CA-1014/ S-SJTIP-18-CA-3035 Grant Award Period: October 1, 2017 through June 30, 2022, October 1, 2018 through December 31, 2022, October 1, 2021 to September 30, 2024 Criteria - §200.516(a) Audit findings(6) requires known or suspected fraud be reported by the auditors. Condition - During the year ended December 31, 2022, the Fund received an e-mail from one of its subrecipients stating that they received a whistleblower complaint about an alleged financial impropriety that occurred within their country office. The subrecipient conducted an internal audit, which confirmed in December 2022 some of the allegations including receipt of per diem for trips not attended and use of an office vehicle and fuel for personal use. In February 2023, the subrecipient also contracted with a consultant to perform a forensic audit of the suspected inappropriate procurement and corruption activities at their Uganda Country office for the period from January 1, 2019 through December 31, 2022. The forensic report highlighted certain amounts that were misappropriated from the PEMS 2 grant for the year ended December 31, 2022. The Fund did not suffer any financial loss, since the Fund subtracted the misappropriated amount from the final disbursement to the subrecipient. In addition, in accordance with 2CFR 200.113, the Fund disclosed the financial impropriety incident to the Office of the Inspector General (OIG) for the Department of State and the cognizant Grants Officer was aware of substantiated misappropriation that impacted funding sub-awarded by the Fund to the subrecipient under the PEMS 2 grant. Cause - Individuals at the subrecipient organization committed inappropriate procurement and corruption activities. Effect - These conditions could result in unallowable expenses being charged to U.S. Government awards if the whistle blower complaint and subsequent investigation did not identify the financial impropriety. Questioned Costs - There are no questioned costs since the Fund subtracted the misappropriated amount from the final disbursement to the subrecipient. Context - This matter was identified through a whistleblower complaint at the subrecipient organization during the year ended December 31, 2022. Repeat Finding - This is not a repeat finding. Recommendation - The Fund should continue to monitor and assess the control environment in which its subrecipients operate. The Fund should also ensure a detailed risk assessment of all subrecipients is regularly performed and reviewed. It should also assess whether future funding be provided to the subrecipient. View of Responsible Officials - Management agrees with the Federal award finding identified in the audit. The Fund’s response to this finding is described in the accompanying management’s corrective action plan.
2022-003 Financial Impropriety Information on Federal Program(s) U.S. Department of State Name of Program: Program to End Modern Slavery Assistance Listing Number: 19.019 Grant Award Number: S-SJTIP-17-CA-1018/S-SJTIP-18-CA-1014/ S-SJTIP-18-CA-3035 Grant Award Period: October 1, 2017 through June 30, 2022, October 1, 2018 through December 31, 2022, October 1, 2021 to September 30, 2024 Criteria - §200.516(a) Audit findings(6) requires known or suspected fraud be reported by the auditors. Condition - During the year ended December 31, 2022, the Fund received an e-mail from one of its subrecipients stating that they received a whistleblower complaint about an alleged financial impropriety that occurred within their country office. The subrecipient conducted an internal audit, which confirmed in December 2022 some of the allegations including receipt of per diem for trips not attended and use of an office vehicle and fuel for personal use. In February 2023, the subrecipient also contracted with a consultant to perform a forensic audit of the suspected inappropriate procurement and corruption activities at their Uganda Country office for the period from January 1, 2019 through December 31, 2022. The forensic report highlighted certain amounts that were misappropriated from the PEMS 2 grant for the year ended December 31, 2022. The Fund did not suffer any financial loss, since the Fund subtracted the misappropriated amount from the final disbursement to the subrecipient. In addition, in accordance with 2CFR 200.113, the Fund disclosed the financial impropriety incident to the Office of the Inspector General (OIG) for the Department of State and the cognizant Grants Officer was aware of substantiated misappropriation that impacted funding sub-awarded by the Fund to the subrecipient under the PEMS 2 grant. Cause - Individuals at the subrecipient organization committed inappropriate procurement and corruption activities. Effect - These conditions could result in unallowable expenses being charged to U.S. Government awards if the whistle blower complaint and subsequent investigation did not identify the financial impropriety. Questioned Costs - There are no questioned costs since the Fund subtracted the misappropriated amount from the final disbursement to the subrecipient. Context - This matter was identified through a whistleblower complaint at the subrecipient organization during the year ended December 31, 2022. Repeat Finding - This is not a repeat finding. Recommendation - The Fund should continue to monitor and assess the control environment in which its subrecipients operate. The Fund should also ensure a detailed risk assessment of all subrecipients is regularly performed and reviewed. It should also assess whether future funding be provided to the subrecipient. View of Responsible Officials - Management agrees with the Federal award finding identified in the audit. The Fund’s response to this finding is described in the accompanying management’s corrective action plan.
According to Section 200.303 of the Uniform Guidance, a nonfederal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Point of Freedom receiving Federal Awards must follow 2 CFR Part 200 subpart E, which outlines cost principles in the Uniform Guidance. Adequate documentation is crucial for costs to be allowable under Federal Awards, ensuring compliance, transparency, and accountability in fund utilization. We noted the following matters during testing: 1) Nineteen (19) contractor expenditures have no internal control evidence of timesheet reviewed and approved for the hours charged to the federal program. 2) Seven (7) disbursements have inadequate documentation. There is no formal monitoring over the contractors’ charged hours to the federal program and established policies over maintaining an adequate documentation. This suggests control deficiency over compliance. Incomplete documentation creates a challenge in promptly verifying the accuracy, thereby posing a risk of improper disbursements of federal funds. Of the 693 disbursements, we examined 68 of which seven (7) were identified with incomplete documentation, nineteen (19) contractor invoices without supporting timesheets. In accordance with 2 CFR 200.516(a)(3), auditors are required to report known questioned costs when likely questioned costs are greater than $25,000. Although the sample uncovered 26 transactions with incomplete documentation, resulting in $11,307 in questioned costs, extending the tests to the entire population projects questioned costs exceeding $25,000, specifically $27,462. We recommend that management should develop internal control procedures to address the compliance requirements of federal programs, especially over retaining adequate documentation of transactions.
Criteria: Regulations require that the Organization must submit the single audit data collection form and reporting package within the earlier of 30 calendar days after receipt of the auditor’s report or 9 months after the end of the audit period, to comply with 2 CFR § 200.512(a)(1). Condition: The Organization submitted their 2021 Single Audit Data Collection form on September 7, 2023, which was 20 months after the end of the audit period. Effect: The Organization did not comply with 2 CFR § 200.512(a)(1). Per 2 CFR § 200.516(a)(2), this results in material noncompliance with the provisions of Federal statues, regulations, and terms and conditions of Federal awards related to major programs. Cause: The Organization failed to submit their 2021 Single Audit Data Collection form before the end of September 2022 – the 9 month post-audit period ending deadline. Recommendations: We recommend management finalize and submit their single audit data collection forms within the 9 month window moving forward. Views of Responsible Officials: The Organization agrees with the finding and will work to implement the recommendations.
1. Summary of auditors' results (i) Type of report issued on the financial statements: Unmodified (ii) Internal control over financial reporting: Material weaknesses identified? No Significant deficiencies identified? Yes, Finding 2022-001 (iii) Noncompliance material to the financial statements noted? No (iv) Internal control over major federal programs: Material weaknesses identified? No Significant deficiencies identified? Yes, Finding 2022-001 (v) Type of report issued on compliance for major programs: Unmodified opinion. (vi) Any audit findings disclosed that are required to be reported in accordance with 2 CFR 200.516(a)? Yes (vii) Major program: Section 202 Capital Advance ALN: 14.157 (viii) Dollar threshold used for distinguishing Types A and B programs: $750,000 (ix) Auditee qualified as a low-risk auditee? No 2. Findings required to be reported in accordance with generally accepted government auditing standards 2022-001: Capital Advance ALN: 14.157 ? Replacement Reserve Deposits ? Finding Resolution Status: In Process ? Information on Universe Population Size: Twelve monthly deposits ? Sample Size Information: Twelve ? Identification of Repeat Finding and Finding Reference Number: 2021-001 ? Criteria: Under the Capital Advance agreement, HUD requires monthly deposits to the replacement reserve account for future capital expenditures.
SUMMARY OF AUDITOR?S RESULTS 1. The Independent Auditor?s Report expresses an unmodified opinion on the financial statements of Genesee Valley Presbyterian Nursing Center d/b/a Kirkhaven, HUD Project 014-43199 (Kirkhaven) prepared in accordance with generally accepted accounting principles. 2. No significant deficiencies or material weaknesses related to the audit of the financial statements are reported in the Independent Auditor?s Report on Internal Control Over Financial Reporting and on Compliance and Other Matters Based on an Audit of Financial Statements Performed in Accordance with Government Auditing Standards. 3. No instances of noncompliance material to the financial statements of Kirkhaven which would be required to be reported in accordance with Government Auditing Standards were disclosed during the audit. 4. No material weaknesses or significant deficiencies were identified relating to the audit of each major federal award program in the Independent Auditor?s Report on Compliance for Each Major Program and on Internal Control Over Compliance Required by the Uniform Guidance. 5. The independent auditor?s report on compliance for Kirkhaven?s major federal award programs expresses an unmodified opinion. 6. Audit finding (2022-001) that is required to be reported in accordance with 2 CFR section 200.516(a) are reported in this schedule. 7. The program tested as a major program was: ? United States Department of Housing and Urban Development (HUD), Assistance Listing No. 14.129 8. The threshold for distinguishing Types A and B programs was $750,000. 9. Kirkhaven was determined to be a low-risk auditee. B. FINDINGS - FINANCIAL STATEMENT AUDIT None. FINDINGS AND QUESTIONED COSTS - MAJOR FEDERAL AWARDS PROGRAM Finding 2022-001 ? Assistance Listing No. 14.129 ? United States Department of Housing and Urban Development Criteria Under the terms of the related regulatory agreement Kirkhaven is required to make timely monthly debt payments and deposits in certain escrow accounts. Condition/Context As part of our compliance testing, we reviewed the debt and escrow schedules and noted that the debt payments and escrow payments due in October through December of 2022 were not made.
SCHEDULE OF FINDINGS AND QUESTIONED COSTS Part A: Summary of Audit Results: 1. The audited financial statements were prepared in accordance with GAAP. 2. The auditor?s report expresses an unmodified opinion on the financial statements of HFF. 3. No material weaknesses were identified in relation to internal control over financial reporting. 4. No significant deficiencies were reported in relation to internal control over financial reporting. 5. No instances of noncompliance material to the financial statements of HFF were disclosed during the audit. 6. No material weaknesses related to internal control over major federal programs were identified during the audit. 7. No significant deficiencies related to internal control over major federal programs were reported during the audit. 8. The auditor?s report on compliance for the major federal award programs for HFF expresses an unmodified opinion. 9. There were no audit findings relative to the major federal award programs for HFF in accordance with 2 CFR 200.516(a). 10. One audit finding was disclosed that is required to be reported in accordance with 2 CFR 200.516(a). 11. Identification of major federal programs: Assistance Listing Number 14.231 12. The programs tested as major programs were: Assistance Listing Number 14.231 13. The threshold for distinguishing Types A and B programs was $750,000. 14. HFF was determined to be a low-risk auditee. Part B: Findings at the financial statement level: None Part C: Findings and Questioned Costs ? Major Federal Award Program Audit: None Findings and Questioned Cost ? Other Matters: 1) Finding 2022-001: Assistance Listing #14.267 US Department of Housing and Urban Development Passed through Community Shelter Board ? Transitional Age Youth Program Condition: Subrecipients not reimbursed on a timely basis. During the period, the Organization oversaw subrecipient grantees under CFDA #14.267. The Organization received and held funds from grantor intended for subrecipients for an amount of time in excess of what is considered timely for reimbursement to the subrecipient. Criteria: This is deemed a matter of untimely subrecipient reimbursement. Cause: The Organization had an incorrect understanding of their role as sub-grantee, in which they believed that additional information was required to be provided by subrecipient before funds were disbursed. Effect: The result is a backlog of monthly reimbursements not disbursed to subrecipient in a timely manner. Recommendations: That the Organization implement controls to align subrecipient reimbursement requests with collection of required subrecipient information, as well as establish a formal timeline for approving reimbursements to subrecipients. Comments: The finding was discussed with Board and Management, and they communicated in the Corrective Action Plan that the Organization will implement additional controls surrounding their subrecipient relationships, and that they consult Uniform Guidance guidelines when implementing these controls. It should be noted that the Organization does not maintain subrecipient relationships under any other federal grants, and hence, the issue at hand does not impact other grants/programs.
U.S. Department of Treasury. Program Name: COVID 19: Emergency Rental Assistance Program. Assistance Listing Number: 21.023. Finding: 21.023. Criteria: In accordance with Uniform Guidance 2 CFR 200.516 - Audit Findings, known or likely fraud affecting a Federal Award, as well as known questioned costs that are greater than $25,000 must be reported as audit findings in the schedule of findings and questioned costs. Condition: Although the County has controls in place to ensure compliance with their Emergency Rental Assistance Program's policies and procedures, which include fraud prevention procedures, fraud did occur. During 2022, the County discovered (and reported to the auditors) that eight (8) landlord applicants committed fraudulent activity that included the submission of documents that were modified electronically prior to their submission, stolen identity, misrepresentation and inability to repay funds within a timely manner. Funds were disbursed to these applicants prior to the County becoming aware of the fraud. Cause: Eight (8) landlord applicants committed fraudulent activity. Effects: Eight (8) applicants received funding, although the fraudulent activity was committed by the applicants. Questioned Costs: $144,692. Recommendation: We recommend the County strengthen procedures and/or implement additional procedures to reduce the potential of fraud occuring. Auditee's Reponse: In addition to continuing to follow the County's policies and procedures developed in accordance with Emergency Rental Assistance guidelines established by the U.S. Department of Treasury, the County implemented additional procedures in May 2022 to enhance fraud prevention activities. The updated procedures required HomeFirst Gwinnett, the subrecipient managing the Emergency Rental Assistance Program, to perform additional verification and approval procedures to detect fraudulent applications before they are presented for payment. HomeFirst Gwinnett would no longer accept documentation that had been completely generated electronically as sole proof of property ownership and added another level of file review of property deed records for landlord property owners utilizing the authorized property deed record website. All assistance above $10,000 will require final review/approval by the HomeFirst Gwinnet director or manager. As new applicants input their information into the County's vendor portal, the Treasury Division in the Department of Financial Services would verify the validity of those records and would not allow the registration to complete unless they met the required criteria. Any suspicious activity was reported to management promptly, and for suspected fraudulent applicants, those applicants accounts were locked as a preventative control so that no future transactions could be processed while the account was under investigation. For individual landlords, ACH payment was no longer an option and they were required to physically present present a valid picture ID to receive a check at the Program Office. Additional training on the revised procedures was provided to program staff. While the additional prevention measures noted above did deter fraudulent attempts made on the program, Gwinnett County tracked and reported eight landlord cases of suspected fraud in 2022. The suspected fraud was forwarded to the Gwinnett County Police Department's (GCPD) Financial Crimes Unit. Any funds recovered will be returned to the U.S. Department of the Treasury. Gwinnett County's emergency rental assistance program, Project RESET 2.0 (PR2.0), concluded on Thursday, December 29, 2022.
FINDING 2022-002 Program Information: COVID-19 Governor?s Emergency Education Relief Fund (84.425C) and COVID-19 Elementary and Secondary School Emergency Relief Fund (84.425U) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR section 200.516(a)(6) (a) The auditor must report the following as audit findings in a schedule of findings and questioned costs: (6) Known or likely fraud affecting a Federal award, unless such fraud is otherwise reported as an audit finding in the schedule of findings and questioned costs for Federal awards. Condition: A subrecipient of the Organization reported alleged fraud arising from grant mismanagement and misuse related to GEER and ESSER funding. Cause: Alleged collusion between employees at the subrecipient entity. Effect or Potential Effect: Unknown at this time. Questioned Costs: Not determinable. Context: Two employees of the subrecipient entity are alleged to have colluded in order to perpetrate fraud against the entity. The alleged fraud is purported to include alleged misappropriation of assets as well as alleged direct financial fraud. Once the Organization was alerted to the fraud, a funding hold was placed on the subrecipient entity, pending the results of ongoing investigations. Both employees alleged to have committed the fraud are no longer employed at the subrecipient organization. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the Organization continue to monitor the various investigations of the alleged fraud currently taking place. We further recommend that the Organization consider requiring subrecipient entities to submit disclosures of any workplace nepotism related to personnel with financial or reporting responsibilities. If personnel with reporting responsibilities are related to one another, the organization should require that subrecipient entities detail what additional review process or internal controls will take place to mitigate potential risks that may arise from workplace nepotism. Views of Responsible Officials and Planned Corrective Actions: Management will continue to closely monitor the situation.
Section III - Federal Award Findings and Questioned Costs (2 CFR 200.516(a)) Finding 2022-001: Payroll Allocations Information on the Federal Programs: 98.001 and 19.519 Criteria or specific requirement (including statutory, regulatory, or other citation): Under 2 CFR 200.430 all charges to federal awards for salaries and wages must be based on records that accurately reflect work performed, and these records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable and properly allocated. Condition: MdMUSA keeps a payroll allocation spreadsheet for each federal grant on a monthly basis to allocate time. MdMUSA determines percentage of time worked on each grant on the basis of hours worked during the month divided by total hours in the month. Instances were noted in which the total number of hours in a month was different for various grants in the same month. Additionally, there were instances in which employee timesheets were changed after the fact, and the finance department had to re-allocate significant values of time to reflect the modified timesheet. Cause: Total hours in the month is a manual input on each grant's allocation sheet and is calculated by multiplying 8 hours times the total number of working days in the month. Instances in which total number of hours in the month varied across different grants were the result of management oversight. There is no documented review and approval of employee timesheets. Effect or Potential Effect: When using the incorrect basis for the number of hours during a month, MdMUSA could inadvertently charge more or less time to certain awards than was actually spent. This could result in the Federal Government over-paying for salaries associated with the award. Additionally, lack of documented supervisory review of timesheets could result in timesheets being incorrect and time not being appropriately allocated to federal awards. Questioned Costs: Not determined. Context: Our audit procedures consisted of testwork performed over various payroll transactions during the year. We consisted our testwork to be representative of the population. The condition appears to be systematic in nature. Identification as a Repeat Finding, if Applicable: Not a repeat finding. Recommendation: We recommend that MdMUSA implement a review process over each grant's monthly payroll allocation sheet. This will ensure that the total hours for the month will be accurate and consistent across all awards. Additionally, we recommend that management implement a monthly review process over employee timesheets. Employee timesheets should be reviewed by an appropriate supervisor, or by the executive director, whichever is appropriate.
Section III - Federal Award Findings and Questioned Costs (2 CFR 200.516(a)) Finding 2022-001: Payroll Allocations Information on the Federal Programs: 98.001 and 19.519 Criteria or specific requirement (including statutory, regulatory, or other citation): Under 2 CFR 200.430 all charges to federal awards for salaries and wages must be based on records that accurately reflect work performed, and these records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable and properly allocated. Condition: MdMUSA keeps a payroll allocation spreadsheet for each federal grant on a monthly basis to allocate time. MdMUSA determines percentage of time worked on each grant on the basis of hours worked during the month divided by total hours in the month. Instances were noted in which the total number of hours in a month was different for various grants in the same month. Additionally, there were instances in which employee timesheets were changed after the fact, and the finance department had to re-allocate significant values of time to reflect the modified timesheet. Cause: Total hours in the month is a manual input on each grant's allocation sheet and is calculated by multiplying 8 hours times the total number of working days in the month. Instances in which total number of hours in the month varied across different grants were the result of management oversight. There is no documented review and approval of employee timesheets. Effect or Potential Effect: When using the incorrect basis for the number of hours during a month, MdMUSA could inadvertently charge more or less time to certain awards than was actually spent. This could result in the Federal Government over-paying for salaries associated with the award. Additionally, lack of documented supervisory review of timesheets could result in timesheets being incorrect and time not being appropriately allocated to federal awards. Questioned Costs: Not determined. Context: Our audit procedures consisted of testwork performed over various payroll transactions during the year. We consisted our testwork to be representative of the population. The condition appears to be systematic in nature. Identification as a Repeat Finding, if Applicable: Not a repeat finding. Recommendation: We recommend that MdMUSA implement a review process over each grant's monthly payroll allocation sheet. This will ensure that the total hours for the month will be accurate and consistent across all awards. Additionally, we recommend that management implement a monthly review process over employee timesheets. Employee timesheets should be reviewed by an appropriate supervisor, or by the executive director, whichever is appropriate.
Section III - Federal Award Findings and Questioned Costs (2 CFR 200.516(a)) Finding 2022-001: Payroll Allocations Information on the Federal Programs: 98.001 and 19.519 Criteria or specific requirement (including statutory, regulatory, or other citation): Under 2 CFR 200.430 all charges to federal awards for salaries and wages must be based on records that accurately reflect work performed, and these records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable and properly allocated. Condition: MdMUSA keeps a payroll allocation spreadsheet for each federal grant on a monthly basis to allocate time. MdMUSA determines percentage of time worked on each grant on the basis of hours worked during the month divided by total hours in the month. Instances were noted in which the total number of hours in a month was different for various grants in the same month. Additionally, there were instances in which employee timesheets were changed after the fact, and the finance department had to re-allocate significant values of time to reflect the modified timesheet. Cause: Total hours in the month is a manual input on each grant's allocation sheet and is calculated by multiplying 8 hours times the total number of working days in the month. Instances in which total number of hours in the month varied across different grants were the result of management oversight. There is no documented review and approval of employee timesheets. Effect or Potential Effect: When using the incorrect basis for the number of hours during a month, MdMUSA could inadvertently charge more or less time to certain awards than was actually spent. This could result in the Federal Government over-paying for salaries associated with the award. Additionally, lack of documented supervisory review of timesheets could result in timesheets being incorrect and time not being appropriately allocated to federal awards. Questioned Costs: Not determined. Context: Our audit procedures consisted of testwork performed over various payroll transactions during the year. We consisted our testwork to be representative of the population. The condition appears to be systematic in nature. Identification as a Repeat Finding, if Applicable: Not a repeat finding. Recommendation: We recommend that MdMUSA implement a review process over each grant's monthly payroll allocation sheet. This will ensure that the total hours for the month will be accurate and consistent across all awards. Additionally, we recommend that management implement a monthly review process over employee timesheets. Employee timesheets should be reviewed by an appropriate supervisor, or by the executive director, whichever is appropriate.
Section III - Federal Award Findings and Questioned Costs (2 CFR 200.516(a)) Finding 2022-001: Payroll Allocations Information on the Federal Programs: 98.001 and 19.519 Criteria or specific requirement (including statutory, regulatory, or other citation): Under 2 CFR 200.430 all charges to federal awards for salaries and wages must be based on records that accurately reflect work performed, and these records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable and properly allocated. Condition: MdMUSA keeps a payroll allocation spreadsheet for each federal grant on a monthly basis to allocate time. MdMUSA determines percentage of time worked on each grant on the basis of hours worked during the month divided by total hours in the month. Instances were noted in which the total number of hours in a month was different for various grants in the same month. Additionally, there were instances in which employee timesheets were changed after the fact, and the finance department had to re-allocate significant values of time to reflect the modified timesheet. Cause: Total hours in the month is a manual input on each grant's allocation sheet and is calculated by multiplying 8 hours times the total number of working days in the month. Instances in which total number of hours in the month varied across different grants were the result of management oversight. There is no documented review and approval of employee timesheets. Effect or Potential Effect: When using the incorrect basis for the number of hours during a month, MdMUSA could inadvertently charge more or less time to certain awards than was actually spent. This could result in the Federal Government over-paying for salaries associated with the award. Additionally, lack of documented supervisory review of timesheets could result in timesheets being incorrect and time not being appropriately allocated to federal awards. Questioned Costs: Not determined. Context: Our audit procedures consisted of testwork performed over various payroll transactions during the year. We consisted our testwork to be representative of the population. The condition appears to be systematic in nature. Identification as a Repeat Finding, if Applicable: Not a repeat finding. Recommendation: We recommend that MdMUSA implement a review process over each grant's monthly payroll allocation sheet. This will ensure that the total hours for the month will be accurate and consistent across all awards. Additionally, we recommend that management implement a monthly review process over employee timesheets. Employee timesheets should be reviewed by an appropriate supervisor, or by the executive director, whichever is appropriate.
Section III - Federal Award Findings and Questioned Costs (2 CFR 200.516(a)) Finding 2022-001: Payroll Allocations Information on the Federal Programs: 98.001 and 19.519 Criteria or specific requirement (including statutory, regulatory, or other citation): Under 2 CFR 200.430 all charges to federal awards for salaries and wages must be based on records that accurately reflect work performed, and these records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable and properly allocated. Condition: MdMUSA keeps a payroll allocation spreadsheet for each federal grant on a monthly basis to allocate time. MdMUSA determines percentage of time worked on each grant on the basis of hours worked during the month divided by total hours in the month. Instances were noted in which the total number of hours in a month was different for various grants in the same month. Additionally, there were instances in which employee timesheets were changed after the fact, and the finance department had to re-allocate significant values of time to reflect the modified timesheet. Cause: Total hours in the month is a manual input on each grant's allocation sheet and is calculated by multiplying 8 hours times the total number of working days in the month. Instances in which total number of hours in the month varied across different grants were the result of management oversight. There is no documented review and approval of employee timesheets. Effect or Potential Effect: When using the incorrect basis for the number of hours during a month, MdMUSA could inadvertently charge more or less time to certain awards than was actually spent. This could result in the Federal Government over-paying for salaries associated with the award. Additionally, lack of documented supervisory review of timesheets could result in timesheets being incorrect and time not being appropriately allocated to federal awards. Questioned Costs: Not determined. Context: Our audit procedures consisted of testwork performed over various payroll transactions during the year. We consisted our testwork to be representative of the population. The condition appears to be systematic in nature. Identification as a Repeat Finding, if Applicable: Not a repeat finding. Recommendation: We recommend that MdMUSA implement a review process over each grant's monthly payroll allocation sheet. This will ensure that the total hours for the month will be accurate and consistent across all awards. Additionally, we recommend that management implement a monthly review process over employee timesheets. Employee timesheets should be reviewed by an appropriate supervisor, or by the executive director, whichever is appropriate.
Section III - Federal Award Findings and Questioned Costs (2 CFR 200.516(a)) Finding 2022-001: Payroll Allocations Information on the Federal Programs: 98.001 and 19.519 Criteria or specific requirement (including statutory, regulatory, or other citation): Under 2 CFR 200.430 all charges to federal awards for salaries and wages must be based on records that accurately reflect work performed, and these records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable and properly allocated. Condition: MdMUSA keeps a payroll allocation spreadsheet for each federal grant on a monthly basis to allocate time. MdMUSA determines percentage of time worked on each grant on the basis of hours worked during the month divided by total hours in the month. Instances were noted in which the total number of hours in a month was different for various grants in the same month. Additionally, there were instances in which employee timesheets were changed after the fact, and the finance department had to re-allocate significant values of time to reflect the modified timesheet. Cause: Total hours in the month is a manual input on each grant's allocation sheet and is calculated by multiplying 8 hours times the total number of working days in the month. Instances in which total number of hours in the month varied across different grants were the result of management oversight. There is no documented review and approval of employee timesheets. Effect or Potential Effect: When using the incorrect basis for the number of hours during a month, MdMUSA could inadvertently charge more or less time to certain awards than was actually spent. This could result in the Federal Government over-paying for salaries associated with the award. Additionally, lack of documented supervisory review of timesheets could result in timesheets being incorrect and time not being appropriately allocated to federal awards. Questioned Costs: Not determined. Context: Our audit procedures consisted of testwork performed over various payroll transactions during the year. We consisted our testwork to be representative of the population. The condition appears to be systematic in nature. Identification as a Repeat Finding, if Applicable: Not a repeat finding. Recommendation: We recommend that MdMUSA implement a review process over each grant's monthly payroll allocation sheet. This will ensure that the total hours for the month will be accurate and consistent across all awards. Additionally, we recommend that management implement a monthly review process over employee timesheets. Employee timesheets should be reviewed by an appropriate supervisor, or by the executive director, whichever is appropriate.
Section III - Federal Award Findings and Questioned Costs (2 CFR 200.516(a)) Finding 2022-001: Payroll Allocations Information on the Federal Programs: 98.001 and 19.519 Criteria or specific requirement (including statutory, regulatory, or other citation): Under 2 CFR 200.430 all charges to federal awards for salaries and wages must be based on records that accurately reflect work performed, and these records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable and properly allocated. Condition: MdMUSA keeps a payroll allocation spreadsheet for each federal grant on a monthly basis to allocate time. MdMUSA determines percentage of time worked on each grant on the basis of hours worked during the month divided by total hours in the month. Instances were noted in which the total number of hours in a month was different for various grants in the same month. Additionally, there were instances in which employee timesheets were changed after the fact, and the finance department had to re-allocate significant values of time to reflect the modified timesheet. Cause: Total hours in the month is a manual input on each grant's allocation sheet and is calculated by multiplying 8 hours times the total number of working days in the month. Instances in which total number of hours in the month varied across different grants were the result of management oversight. There is no documented review and approval of employee timesheets. Effect or Potential Effect: When using the incorrect basis for the number of hours during a month, MdMUSA could inadvertently charge more or less time to certain awards than was actually spent. This could result in the Federal Government over-paying for salaries associated with the award. Additionally, lack of documented supervisory review of timesheets could result in timesheets being incorrect and time not being appropriately allocated to federal awards. Questioned Costs: Not determined. Context: Our audit procedures consisted of testwork performed over various payroll transactions during the year. We consisted our testwork to be representative of the population. The condition appears to be systematic in nature. Identification as a Repeat Finding, if Applicable: Not a repeat finding. Recommendation: We recommend that MdMUSA implement a review process over each grant's monthly payroll allocation sheet. This will ensure that the total hours for the month will be accurate and consistent across all awards. Additionally, we recommend that management implement a monthly review process over employee timesheets. Employee timesheets should be reviewed by an appropriate supervisor, or by the executive director, whichever is appropriate.
Section III - Federal Award Findings and Questioned Costs (2 CFR 200.516(a)) Finding 2022-001: Payroll Allocations Information on the Federal Programs: 98.001 and 19.519 Criteria or specific requirement (including statutory, regulatory, or other citation): Under 2 CFR 200.430 all charges to federal awards for salaries and wages must be based on records that accurately reflect work performed, and these records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable and properly allocated. Condition: MdMUSA keeps a payroll allocation spreadsheet for each federal grant on a monthly basis to allocate time. MdMUSA determines percentage of time worked on each grant on the basis of hours worked during the month divided by total hours in the month. Instances were noted in which the total number of hours in a month was different for various grants in the same month. Additionally, there were instances in which employee timesheets were changed after the fact, and the finance department had to re-allocate significant values of time to reflect the modified timesheet. Cause: Total hours in the month is a manual input on each grant's allocation sheet and is calculated by multiplying 8 hours times the total number of working days in the month. Instances in which total number of hours in the month varied across different grants were the result of management oversight. There is no documented review and approval of employee timesheets. Effect or Potential Effect: When using the incorrect basis for the number of hours during a month, MdMUSA could inadvertently charge more or less time to certain awards than was actually spent. This could result in the Federal Government over-paying for salaries associated with the award. Additionally, lack of documented supervisory review of timesheets could result in timesheets being incorrect and time not being appropriately allocated to federal awards. Questioned Costs: Not determined. Context: Our audit procedures consisted of testwork performed over various payroll transactions during the year. We consisted our testwork to be representative of the population. The condition appears to be systematic in nature. Identification as a Repeat Finding, if Applicable: Not a repeat finding. Recommendation: We recommend that MdMUSA implement a review process over each grant's monthly payroll allocation sheet. This will ensure that the total hours for the month will be accurate and consistent across all awards. Additionally, we recommend that management implement a monthly review process over employee timesheets. Employee timesheets should be reviewed by an appropriate supervisor, or by the executive director, whichever is appropriate.
Section III - Federal Award Findings and Questioned Costs (2 CFR 200.516(a)) Finding 2022-001: Payroll Allocations Information on the Federal Programs: 98.001 and 19.519 Criteria or specific requirement (including statutory, regulatory, or other citation): Under 2 CFR 200.430 all charges to federal awards for salaries and wages must be based on records that accurately reflect work performed, and these records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable and properly allocated. Condition: MdMUSA keeps a payroll allocation spreadsheet for each federal grant on a monthly basis to allocate time. MdMUSA determines percentage of time worked on each grant on the basis of hours worked during the month divided by total hours in the month. Instances were noted in which the total number of hours in a month was different for various grants in the same month. Additionally, there were instances in which employee timesheets were changed after the fact, and the finance department had to re-allocate significant values of time to reflect the modified timesheet. Cause: Total hours in the month is a manual input on each grant's allocation sheet and is calculated by multiplying 8 hours times the total number of working days in the month. Instances in which total number of hours in the month varied across different grants were the result of management oversight. There is no documented review and approval of employee timesheets. Effect or Potential Effect: When using the incorrect basis for the number of hours during a month, MdMUSA could inadvertently charge more or less time to certain awards than was actually spent. This could result in the Federal Government over-paying for salaries associated with the award. Additionally, lack of documented supervisory review of timesheets could result in timesheets being incorrect and time not being appropriately allocated to federal awards. Questioned Costs: Not determined. Context: Our audit procedures consisted of testwork performed over various payroll transactions during the year. We consisted our testwork to be representative of the population. The condition appears to be systematic in nature. Identification as a Repeat Finding, if Applicable: Not a repeat finding. Recommendation: We recommend that MdMUSA implement a review process over each grant's monthly payroll allocation sheet. This will ensure that the total hours for the month will be accurate and consistent across all awards. Additionally, we recommend that management implement a monthly review process over employee timesheets. Employee timesheets should be reviewed by an appropriate supervisor, or by the executive director, whichever is appropriate.
Section III - Federal Award Findings and Questioned Costs (2 CFR 200.516(a)) Finding 2022-001: Payroll Allocations Information on the Federal Programs: 98.001 and 19.519 Criteria or specific requirement (including statutory, regulatory, or other citation): Under 2 CFR 200.430 all charges to federal awards for salaries and wages must be based on records that accurately reflect work performed, and these records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable and properly allocated. Condition: MdMUSA keeps a payroll allocation spreadsheet for each federal grant on a monthly basis to allocate time. MdMUSA determines percentage of time worked on each grant on the basis of hours worked during the month divided by total hours in the month. Instances were noted in which the total number of hours in a month was different for various grants in the same month. Additionally, there were instances in which employee timesheets were changed after the fact, and the finance department had to re-allocate significant values of time to reflect the modified timesheet. Cause: Total hours in the month is a manual input on each grant's allocation sheet and is calculated by multiplying 8 hours times the total number of working days in the month. Instances in which total number of hours in the month varied across different grants were the result of management oversight. There is no documented review and approval of employee timesheets. Effect or Potential Effect: When using the incorrect basis for the number of hours during a month, MdMUSA could inadvertently charge more or less time to certain awards than was actually spent. This could result in the Federal Government over-paying for salaries associated with the award. Additionally, lack of documented supervisory review of timesheets could result in timesheets being incorrect and time not being appropriately allocated to federal awards. Questioned Costs: Not determined. Context: Our audit procedures consisted of testwork performed over various payroll transactions during the year. We consisted our testwork to be representative of the population. The condition appears to be systematic in nature. Identification as a Repeat Finding, if Applicable: Not a repeat finding. Recommendation: We recommend that MdMUSA implement a review process over each grant's monthly payroll allocation sheet. This will ensure that the total hours for the month will be accurate and consistent across all awards. Additionally, we recommend that management implement a monthly review process over employee timesheets. Employee timesheets should be reviewed by an appropriate supervisor, or by the executive director, whichever is appropriate.
Section III - Federal Award Findings and Questioned Costs (2 CFR 200.516(a)) Finding 2022-001: Payroll Allocations Information on the Federal Programs: 98.001 and 19.519 Criteria or specific requirement (including statutory, regulatory, or other citation): Under 2 CFR 200.430 all charges to federal awards for salaries and wages must be based on records that accurately reflect work performed, and these records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable and properly allocated. Condition: MdMUSA keeps a payroll allocation spreadsheet for each federal grant on a monthly basis to allocate time. MdMUSA determines percentage of time worked on each grant on the basis of hours worked during the month divided by total hours in the month. Instances were noted in which the total number of hours in a month was different for various grants in the same month. Additionally, there were instances in which employee timesheets were changed after the fact, and the finance department had to re-allocate significant values of time to reflect the modified timesheet. Cause: Total hours in the month is a manual input on each grant's allocation sheet and is calculated by multiplying 8 hours times the total number of working days in the month. Instances in which total number of hours in the month varied across different grants were the result of management oversight. There is no documented review and approval of employee timesheets. Effect or Potential Effect: When using the incorrect basis for the number of hours during a month, MdMUSA could inadvertently charge more or less time to certain awards than was actually spent. This could result in the Federal Government over-paying for salaries associated with the award. Additionally, lack of documented supervisory review of timesheets could result in timesheets being incorrect and time not being appropriately allocated to federal awards. Questioned Costs: Not determined. Context: Our audit procedures consisted of testwork performed over various payroll transactions during the year. We consisted our testwork to be representative of the population. The condition appears to be systematic in nature. Identification as a Repeat Finding, if Applicable: Not a repeat finding. Recommendation: We recommend that MdMUSA implement a review process over each grant's monthly payroll allocation sheet. This will ensure that the total hours for the month will be accurate and consistent across all awards. Additionally, we recommend that management implement a monthly review process over employee timesheets. Employee timesheets should be reviewed by an appropriate supervisor, or by the executive director, whichever is appropriate.
Section III - Federal Award Findings and Questioned Costs (2 CFR 200.516(a)) Finding 2022-001: Payroll Allocations Information on the Federal Programs: 98.001 and 19.519 Criteria or specific requirement (including statutory, regulatory, or other citation): Under 2 CFR 200.430 all charges to federal awards for salaries and wages must be based on records that accurately reflect work performed, and these records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable and properly allocated. Condition: MdMUSA keeps a payroll allocation spreadsheet for each federal grant on a monthly basis to allocate time. MdMUSA determines percentage of time worked on each grant on the basis of hours worked during the month divided by total hours in the month. Instances were noted in which the total number of hours in a month was different for various grants in the same month. Additionally, there were instances in which employee timesheets were changed after the fact, and the finance department had to re-allocate significant values of time to reflect the modified timesheet. Cause: Total hours in the month is a manual input on each grant's allocation sheet and is calculated by multiplying 8 hours times the total number of working days in the month. Instances in which total number of hours in the month varied across different grants were the result of management oversight. There is no documented review and approval of employee timesheets. Effect or Potential Effect: When using the incorrect basis for the number of hours during a month, MdMUSA could inadvertently charge more or less time to certain awards than was actually spent. This could result in the Federal Government over-paying for salaries associated with the award. Additionally, lack of documented supervisory review of timesheets could result in timesheets being incorrect and time not being appropriately allocated to federal awards. Questioned Costs: Not determined. Context: Our audit procedures consisted of testwork performed over various payroll transactions during the year. We consisted our testwork to be representative of the population. The condition appears to be systematic in nature. Identification as a Repeat Finding, if Applicable: Not a repeat finding. Recommendation: We recommend that MdMUSA implement a review process over each grant's monthly payroll allocation sheet. This will ensure that the total hours for the month will be accurate and consistent across all awards. Additionally, we recommend that management implement a monthly review process over employee timesheets. Employee timesheets should be reviewed by an appropriate supervisor, or by the executive director, whichever is appropriate.
2022-001 Eligibility Housing Voucher Cluster Continuum of Care Program AL No. 14.267 Other Matter required to be reported under 2 CFR 200.516(a) Condition: Out of an approximate population of 43,000 tenants in the Housing Voucher Cluster programs, 44 tenant files were tested and the following deficiencies were noted: ? 8 files did not receive an annual recertification within the required compliance timeframe. ? 4 of which were completed within 13 months ? 2 files did not include adequate income support. Out of an approximate population of 3,500 tenants in the Continuum of Care Program, 44 tenant files were tested and the following deficiencies were noted: ? 12 files did not receive an annual recertification within the required compliance timeframe. ? 6 of which were completed within 13 months ? 2 files did not include adequate income support. ? 2 files were missing 9886 forms effective for the fiscal year. Criteria: The Authority?s Administrative Plan, 24 CFR 982.516, 24 CFR 578 and the Authority?s Continuum of Care Policies require internal controls to be in place to ensure proper procedures are being followed in compliance with HUD requirements regarding timely, complete and accurate tenant files. Context: The auditor randomly selected 44 tenant files out of each program?s population, which we consider to be a statistically valid sample size. The auditor reviewed the tenant files and support to ensure that proper procedures are being followed and that the Authority is in compliance with HUD requirements regarding timely, complete, and accurate tenant files. Cause: The Authority experienced staffing and operational challenges during the onset of the COVID-19 pandemic. Those challenges have continued although the CARES Act Wavers expired on December 31, 2021. Additionally, a significant portion of the population being served are transient in nature and obtaining timely and accurate information is challenging. Effect: The Authority is not in compliance with HUD requirements regarding eligibility which could result in the incorrect amount of rental assistance provided. Questioned Costs: None. Auditor Recommendations: The Authority should consider reevaluating their established procedures and controls currently in place to ensure full compliance in regards to eligibility and the timeliness of recertifications. The Authority needs to correct the deficiencies noted in the tested files and consider the impact to the rest of the population of tenant files that were not selected as part of the auditor?s sample. Management Response: See Corrective Action Plan.
2022-001 Eligibility Housing Voucher Cluster Continuum of Care Program AL No. 14.267 Other Matter required to be reported under 2 CFR 200.516(a) Condition: Out of an approximate population of 43,000 tenants in the Housing Voucher Cluster programs, 44 tenant files were tested and the following deficiencies were noted: ? 8 files did not receive an annual recertification within the required compliance timeframe. ? 4 of which were completed within 13 months ? 2 files did not include adequate income support. Out of an approximate population of 3,500 tenants in the Continuum of Care Program, 44 tenant files were tested and the following deficiencies were noted: ? 12 files did not receive an annual recertification within the required compliance timeframe. ? 6 of which were completed within 13 months ? 2 files did not include adequate income support. ? 2 files were missing 9886 forms effective for the fiscal year. Criteria: The Authority?s Administrative Plan, 24 CFR 982.516, 24 CFR 578 and the Authority?s Continuum of Care Policies require internal controls to be in place to ensure proper procedures are being followed in compliance with HUD requirements regarding timely, complete and accurate tenant files. Context: The auditor randomly selected 44 tenant files out of each program?s population, which we consider to be a statistically valid sample size. The auditor reviewed the tenant files and support to ensure that proper procedures are being followed and that the Authority is in compliance with HUD requirements regarding timely, complete, and accurate tenant files. Cause: The Authority experienced staffing and operational challenges during the onset of the COVID-19 pandemic. Those challenges have continued although the CARES Act Wavers expired on December 31, 2021. Additionally, a significant portion of the population being served are transient in nature and obtaining timely and accurate information is challenging. Effect: The Authority is not in compliance with HUD requirements regarding eligibility which could result in the incorrect amount of rental assistance provided. Questioned Costs: None. Auditor Recommendations: The Authority should consider reevaluating their established procedures and controls currently in place to ensure full compliance in regards to eligibility and the timeliness of recertifications. The Authority needs to correct the deficiencies noted in the tested files and consider the impact to the rest of the population of tenant files that were not selected as part of the auditor?s sample. Management Response: See Corrective Action Plan.
2022-001 Eligibility Housing Voucher Cluster Continuum of Care Program AL No. 14.267 Other Matter required to be reported under 2 CFR 200.516(a) Condition: Out of an approximate population of 43,000 tenants in the Housing Voucher Cluster programs, 44 tenant files were tested and the following deficiencies were noted: ? 8 files did not receive an annual recertification within the required compliance timeframe. ? 4 of which were completed within 13 months ? 2 files did not include adequate income support. Out of an approximate population of 3,500 tenants in the Continuum of Care Program, 44 tenant files were tested and the following deficiencies were noted: ? 12 files did not receive an annual recertification within the required compliance timeframe. ? 6 of which were completed within 13 months ? 2 files did not include adequate income support. ? 2 files were missing 9886 forms effective for the fiscal year. Criteria: The Authority?s Administrative Plan, 24 CFR 982.516, 24 CFR 578 and the Authority?s Continuum of Care Policies require internal controls to be in place to ensure proper procedures are being followed in compliance with HUD requirements regarding timely, complete and accurate tenant files. Context: The auditor randomly selected 44 tenant files out of each program?s population, which we consider to be a statistically valid sample size. The auditor reviewed the tenant files and support to ensure that proper procedures are being followed and that the Authority is in compliance with HUD requirements regarding timely, complete, and accurate tenant files. Cause: The Authority experienced staffing and operational challenges during the onset of the COVID-19 pandemic. Those challenges have continued although the CARES Act Wavers expired on December 31, 2021. Additionally, a significant portion of the population being served are transient in nature and obtaining timely and accurate information is challenging. Effect: The Authority is not in compliance with HUD requirements regarding eligibility which could result in the incorrect amount of rental assistance provided. Questioned Costs: None. Auditor Recommendations: The Authority should consider reevaluating their established procedures and controls currently in place to ensure full compliance in regards to eligibility and the timeliness of recertifications. The Authority needs to correct the deficiencies noted in the tested files and consider the impact to the rest of the population of tenant files that were not selected as part of the auditor?s sample. Management Response: See Corrective Action Plan.
2022-001 Eligibility Housing Voucher Cluster Continuum of Care Program AL No. 14.267 Other Matter required to be reported under 2 CFR 200.516(a) Condition: Out of an approximate population of 43,000 tenants in the Housing Voucher Cluster programs, 44 tenant files were tested and the following deficiencies were noted: ? 8 files did not receive an annual recertification within the required compliance timeframe. ? 4 of which were completed within 13 months ? 2 files did not include adequate income support. Out of an approximate population of 3,500 tenants in the Continuum of Care Program, 44 tenant files were tested and the following deficiencies were noted: ? 12 files did not receive an annual recertification within the required compliance timeframe. ? 6 of which were completed within 13 months ? 2 files did not include adequate income support. ? 2 files were missing 9886 forms effective for the fiscal year. Criteria: The Authority?s Administrative Plan, 24 CFR 982.516, 24 CFR 578 and the Authority?s Continuum of Care Policies require internal controls to be in place to ensure proper procedures are being followed in compliance with HUD requirements regarding timely, complete and accurate tenant files. Context: The auditor randomly selected 44 tenant files out of each program?s population, which we consider to be a statistically valid sample size. The auditor reviewed the tenant files and support to ensure that proper procedures are being followed and that the Authority is in compliance with HUD requirements regarding timely, complete, and accurate tenant files. Cause: The Authority experienced staffing and operational challenges during the onset of the COVID-19 pandemic. Those challenges have continued although the CARES Act Wavers expired on December 31, 2021. Additionally, a significant portion of the population being served are transient in nature and obtaining timely and accurate information is challenging. Effect: The Authority is not in compliance with HUD requirements regarding eligibility which could result in the incorrect amount of rental assistance provided. Questioned Costs: None. Auditor Recommendations: The Authority should consider reevaluating their established procedures and controls currently in place to ensure full compliance in regards to eligibility and the timeliness of recertifications. The Authority needs to correct the deficiencies noted in the tested files and consider the impact to the rest of the population of tenant files that were not selected as part of the auditor?s sample. Management Response: See Corrective Action Plan.
2022-003 Financial Impropriety Information on Federal Program(s) U.S. Department of State Name of Program: Program to End Modern Slavery Assistance Listing Number: 19.019 Grant Award Number: S-SJTIP-17-CA-1018/S-SJTIP-18-CA-1014/ S-SJTIP-18-CA-3035 Grant Award Period: October 1, 2017 through June 30, 2022, October 1, 2018 through December 31, 2022, October 1, 2021 to September 30, 2024 Criteria - §200.516(a) Audit findings(6) requires known or suspected fraud be reported by the auditors. Condition - During the year ended December 31, 2022, the Fund received an e-mail from one of its subrecipients stating that they received a whistleblower complaint about an alleged financial impropriety that occurred within their country office. The subrecipient conducted an internal audit, which confirmed in December 2022 some of the allegations including receipt of per diem for trips not attended and use of an office vehicle and fuel for personal use. In February 2023, the subrecipient also contracted with a consultant to perform a forensic audit of the suspected inappropriate procurement and corruption activities at their Uganda Country office for the period from January 1, 2019 through December 31, 2022. The forensic report highlighted certain amounts that were misappropriated from the PEMS 2 grant for the year ended December 31, 2022. The Fund did not suffer any financial loss, since the Fund subtracted the misappropriated amount from the final disbursement to the subrecipient. In addition, in accordance with 2CFR 200.113, the Fund disclosed the financial impropriety incident to the Office of the Inspector General (OIG) for the Department of State and the cognizant Grants Officer was aware of substantiated misappropriation that impacted funding sub-awarded by the Fund to the subrecipient under the PEMS 2 grant. Cause - Individuals at the subrecipient organization committed inappropriate procurement and corruption activities. Effect - These conditions could result in unallowable expenses being charged to U.S. Government awards if the whistle blower complaint and subsequent investigation did not identify the financial impropriety. Questioned Costs - There are no questioned costs since the Fund subtracted the misappropriated amount from the final disbursement to the subrecipient. Context - This matter was identified through a whistleblower complaint at the subrecipient organization during the year ended December 31, 2022. Repeat Finding - This is not a repeat finding. Recommendation - The Fund should continue to monitor and assess the control environment in which its subrecipients operate. The Fund should also ensure a detailed risk assessment of all subrecipients is regularly performed and reviewed. It should also assess whether future funding be provided to the subrecipient. View of Responsible Officials - Management agrees with the Federal award finding identified in the audit. The Fund’s response to this finding is described in the accompanying management’s corrective action plan.
2022-003 Financial Impropriety Information on Federal Program(s) U.S. Department of State Name of Program: Program to End Modern Slavery Assistance Listing Number: 19.019 Grant Award Number: S-SJTIP-17-CA-1018/S-SJTIP-18-CA-1014/ S-SJTIP-18-CA-3035 Grant Award Period: October 1, 2017 through June 30, 2022, October 1, 2018 through December 31, 2022, October 1, 2021 to September 30, 2024 Criteria - §200.516(a) Audit findings(6) requires known or suspected fraud be reported by the auditors. Condition - During the year ended December 31, 2022, the Fund received an e-mail from one of its subrecipients stating that they received a whistleblower complaint about an alleged financial impropriety that occurred within their country office. The subrecipient conducted an internal audit, which confirmed in December 2022 some of the allegations including receipt of per diem for trips not attended and use of an office vehicle and fuel for personal use. In February 2023, the subrecipient also contracted with a consultant to perform a forensic audit of the suspected inappropriate procurement and corruption activities at their Uganda Country office for the period from January 1, 2019 through December 31, 2022. The forensic report highlighted certain amounts that were misappropriated from the PEMS 2 grant for the year ended December 31, 2022. The Fund did not suffer any financial loss, since the Fund subtracted the misappropriated amount from the final disbursement to the subrecipient. In addition, in accordance with 2CFR 200.113, the Fund disclosed the financial impropriety incident to the Office of the Inspector General (OIG) for the Department of State and the cognizant Grants Officer was aware of substantiated misappropriation that impacted funding sub-awarded by the Fund to the subrecipient under the PEMS 2 grant. Cause - Individuals at the subrecipient organization committed inappropriate procurement and corruption activities. Effect - These conditions could result in unallowable expenses being charged to U.S. Government awards if the whistle blower complaint and subsequent investigation did not identify the financial impropriety. Questioned Costs - There are no questioned costs since the Fund subtracted the misappropriated amount from the final disbursement to the subrecipient. Context - This matter was identified through a whistleblower complaint at the subrecipient organization during the year ended December 31, 2022. Repeat Finding - This is not a repeat finding. Recommendation - The Fund should continue to monitor and assess the control environment in which its subrecipients operate. The Fund should also ensure a detailed risk assessment of all subrecipients is regularly performed and reviewed. It should also assess whether future funding be provided to the subrecipient. View of Responsible Officials - Management agrees with the Federal award finding identified in the audit. The Fund’s response to this finding is described in the accompanying management’s corrective action plan.
2022-003 Financial Impropriety Information on Federal Program(s) U.S. Department of State Name of Program: Program to End Modern Slavery Assistance Listing Number: 19.019 Grant Award Number: S-SJTIP-17-CA-1018/S-SJTIP-18-CA-1014/ S-SJTIP-18-CA-3035 Grant Award Period: October 1, 2017 through June 30, 2022, October 1, 2018 through December 31, 2022, October 1, 2021 to September 30, 2024 Criteria - §200.516(a) Audit findings(6) requires known or suspected fraud be reported by the auditors. Condition - During the year ended December 31, 2022, the Fund received an e-mail from one of its subrecipients stating that they received a whistleblower complaint about an alleged financial impropriety that occurred within their country office. The subrecipient conducted an internal audit, which confirmed in December 2022 some of the allegations including receipt of per diem for trips not attended and use of an office vehicle and fuel for personal use. In February 2023, the subrecipient also contracted with a consultant to perform a forensic audit of the suspected inappropriate procurement and corruption activities at their Uganda Country office for the period from January 1, 2019 through December 31, 2022. The forensic report highlighted certain amounts that were misappropriated from the PEMS 2 grant for the year ended December 31, 2022. The Fund did not suffer any financial loss, since the Fund subtracted the misappropriated amount from the final disbursement to the subrecipient. In addition, in accordance with 2CFR 200.113, the Fund disclosed the financial impropriety incident to the Office of the Inspector General (OIG) for the Department of State and the cognizant Grants Officer was aware of substantiated misappropriation that impacted funding sub-awarded by the Fund to the subrecipient under the PEMS 2 grant. Cause - Individuals at the subrecipient organization committed inappropriate procurement and corruption activities. Effect - These conditions could result in unallowable expenses being charged to U.S. Government awards if the whistle blower complaint and subsequent investigation did not identify the financial impropriety. Questioned Costs - There are no questioned costs since the Fund subtracted the misappropriated amount from the final disbursement to the subrecipient. Context - This matter was identified through a whistleblower complaint at the subrecipient organization during the year ended December 31, 2022. Repeat Finding - This is not a repeat finding. Recommendation - The Fund should continue to monitor and assess the control environment in which its subrecipients operate. The Fund should also ensure a detailed risk assessment of all subrecipients is regularly performed and reviewed. It should also assess whether future funding be provided to the subrecipient. View of Responsible Officials - Management agrees with the Federal award finding identified in the audit. The Fund’s response to this finding is described in the accompanying management’s corrective action plan.
According to Section 200.303 of the Uniform Guidance, a nonfederal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Point of Freedom receiving Federal Awards must follow 2 CFR Part 200 subpart E, which outlines cost principles in the Uniform Guidance. Adequate documentation is crucial for costs to be allowable under Federal Awards, ensuring compliance, transparency, and accountability in fund utilization. We noted the following matters during testing: 1) Nineteen (19) contractor expenditures have no internal control evidence of timesheet reviewed and approved for the hours charged to the federal program. 2) Seven (7) disbursements have inadequate documentation. There is no formal monitoring over the contractors’ charged hours to the federal program and established policies over maintaining an adequate documentation. This suggests control deficiency over compliance. Incomplete documentation creates a challenge in promptly verifying the accuracy, thereby posing a risk of improper disbursements of federal funds. Of the 693 disbursements, we examined 68 of which seven (7) were identified with incomplete documentation, nineteen (19) contractor invoices without supporting timesheets. In accordance with 2 CFR 200.516(a)(3), auditors are required to report known questioned costs when likely questioned costs are greater than $25,000. Although the sample uncovered 26 transactions with incomplete documentation, resulting in $11,307 in questioned costs, extending the tests to the entire population projects questioned costs exceeding $25,000, specifically $27,462. We recommend that management should develop internal control procedures to address the compliance requirements of federal programs, especially over retaining adequate documentation of transactions.
Criteria: Regulations require that the Organization must submit the single audit data collection form and reporting package within the earlier of 30 calendar days after receipt of the auditor’s report or 9 months after the end of the audit period, to comply with 2 CFR § 200.512(a)(1). Condition: The Organization submitted their 2021 Single Audit Data Collection form on September 7, 2023, which was 20 months after the end of the audit period. Effect: The Organization did not comply with 2 CFR § 200.512(a)(1). Per 2 CFR § 200.516(a)(2), this results in material noncompliance with the provisions of Federal statues, regulations, and terms and conditions of Federal awards related to major programs. Cause: The Organization failed to submit their 2021 Single Audit Data Collection form before the end of September 2022 – the 9 month post-audit period ending deadline. Recommendations: We recommend management finalize and submit their single audit data collection forms within the 9 month window moving forward. Views of Responsible Officials: The Organization agrees with the finding and will work to implement the recommendations.
2022-002 Special Tests and Provisions - SEMAP Housing Voucher Cluster Other matter required to be reported in accordance 2 CFR 200.516(a) Condition: During our audit of the Authority?s SEMAP submission and discussion with the Authority staff, we noted that the Authority did not have proper documentation to support the selections made for the Authority?s annual SEMAP submission. Context: We obtained the Authority?s SEMAP submission and available support documentation. As a part of the testing process we attempted to review the Authority?s sampling and testing methodology for the SEMAP indicators. We were unable to determine that the correct sampling was performed and that the correct testing conclusion were selected with the available documentation. Criteria: 24 CFR 985.2 and 985.3 outlines sampling and testing methodologies for each indicator to allow the Authority to select the correct sample size from the correct universe and to correctly test and report the sample. Cause: The Authority is building the annual SEMAP submission into its procedures again after years of waivers not requiring the SEMAP submission due to COVID. Effect: The Authority is unable to support any selection methodology or testing conclusion performed as part of the annual SEMAP submission. Auditor?s Recommendations: The Authority should prepare and keep documentation to clearly outline the testing performed as a part of the SEMAP submission and the conclusion of each testing items.
2022-002 Special Tests and Provisions - SEMAP Housing Voucher Cluster Other matter required to be reported in accordance 2 CFR 200.516(a) Condition: During our audit of the Authority?s SEMAP submission and discussion with the Authority staff, we noted that the Authority did not have proper documentation to support the selections made for the Authority?s annual SEMAP submission. Context: We obtained the Authority?s SEMAP submission and available support documentation. As a part of the testing process we attempted to review the Authority?s sampling and testing methodology for the SEMAP indicators. We were unable to determine that the correct sampling was performed and that the correct testing conclusion were selected with the available documentation. Criteria: 24 CFR 985.2 and 985.3 outlines sampling and testing methodologies for each indicator to allow the Authority to select the correct sample size from the correct universe and to correctly test and report the sample. Cause: The Authority is building the annual SEMAP submission into its procedures again after years of waivers not requiring the SEMAP submission due to COVID. Effect: The Authority is unable to support any selection methodology or testing conclusion performed as part of the annual SEMAP submission. Auditor?s Recommendations: The Authority should prepare and keep documentation to clearly outline the testing performed as a part of the SEMAP submission and the conclusion of each testing items.
2022-002 Special Tests and Provisions - SEMAP Housing Voucher Cluster Other matter required to be reported in accordance 2 CFR 200.516(a) Condition: During our audit of the Authority?s SEMAP submission and discussion with the Authority staff, we noted that the Authority did not have proper documentation to support the selections made for the Authority?s annual SEMAP submission. Context: We obtained the Authority?s SEMAP submission and available support documentation. As a part of the testing process we attempted to review the Authority?s sampling and testing methodology for the SEMAP indicators. We were unable to determine that the correct sampling was performed and that the correct testing conclusion were selected with the available documentation. Criteria: 24 CFR 985.2 and 985.3 outlines sampling and testing methodologies for each indicator to allow the Authority to select the correct sample size from the correct universe and to correctly test and report the sample. Cause: The Authority is building the annual SEMAP submission into its procedures again after years of waivers not requiring the SEMAP submission due to COVID. Effect: The Authority is unable to support any selection methodology or testing conclusion performed as part of the annual SEMAP submission. Auditor?s Recommendations: The Authority should prepare and keep documentation to clearly outline the testing performed as a part of the SEMAP submission and the conclusion of each testing items.
FINDING 2022-031 Pandemic EBT Food Benefits, ALN 10.542, Activities Allowed or Unallowed and Eligibility - Overpayment of Benefits See Schedule of Findings and Questioned Costs for chart/table. Condition MDHHS did not always ensure accurate P-EBT benefits were provided to eligible beneficiaries. We noted for 1 (4%) of the 26 sampled cases reviewed, MDHHS duplicated the summer benefits resulting in an overpayment of $782. Criteria The Families First Coronavirus Response Act of 2020 (Public Law 116-127), as amended, requires MDHHS to have an approved state plan to provide P-EBT food benefits to households with children who would otherwise receive free or reduced-price meals if not for their schools being closed because of the COVID-19 emergency. MDHHS's P-EBT State Plan states it will provide the standard benefit amount for the summer period and will identify the eligible children based on eligibility in the last month of the school year. Cause MDHHS informed us that because of the timing of the 2022-2023 school enrollment for these children, a system error duplicated the 2022 summer benefits. Effect MDHHS overpaid P-EBT benefits by $782 for the sampled cases. The federal grantor agency could issue sanctions or disallowances related to noncompliance. Known Questioned Costs Federal regulation 2 CFR 200.516(a)(3) requires the auditor to report known questioned costs that are less than $25,000 if it is likely total questioned costs would exceed $25,000. ? $782 ? federal share. Recommendation We recommend MDHHS ensure accurate P-EBT benefits are provided to eligible beneficiaries. Management Views MDHHS agrees with the finding.
FINDING 2022-041 Homeowner Assistance Fund, ALN 21.026, Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Eligibility - Eligibility Determinations See Schedule of Findings and Questioned Costs for chart/table. Condition MSHDA did not obtain and maintain sufficient documentation to support the Homeowner Assistance Fund (HAF) applicants' eligibility was properly determined for 3 (12%) of 25 HAF assistance payments reviewed. We noted: a. For 1 (4%) applicant, sufficient documentation did not exist to support the applicant's eligibility. Contradictory information was provided by the applicant as to the hardship encountered from the COVID-19 pandemic. MSHDA did not detect this at the time of its review and, therefore, did not follow up with the applicant. b. For 1 (4%) applicant, MSHDA did not document the required income calculation to support the homeowner met the income eligibility requirement. We performed this calculation and determined the client was eligible for HAF assistance. c. For 1 (4%) applicant, MSHDA did not ensure its system checklist was completed prior to approving for eligibility. We determined this did not affect the applicant's eligibility. Criteria Subpart E of federal regulation 2 CFR 200 requires costs charged to federal programs be adequately documented, be necessary and reasonable for the administration of the federal award, be in accordance with the relative benefits received by the program, and be consistent with policies and procedures that apply to both the federal award and other activities of the state. The HAF guidance requires homeowners to attest that they experienced financial hardship after January 21, 2020 associated with the coronavirus pandemic. A financial hardship is defined as a material reduction in income or a material increase in expenses. The attestation must describe the nature of the financial hardship. MSHDA's internal policy requires case managers to verify and calculate homeowner income during their determination of eligibility in the initial review of the application. Case managers must record their calculations within the activity log. Calculations are performed to determine annual income utilizing supporting documentation. In addition, case managers must use a system checklist to ensure all parts of the application have been reviewed prior to approving the homeowner's eligibility. Cause MSHDA informed us these errors resulted from employee oversight. Effect MSHDA may have provided assistance to ineligible applicants. The federal grantor agency could issue sanctions or disallowances related to noncompliance. Known Questioned Costs Federal regulation 2 CFR 200.516(a)(3) requires the auditor to report known questioned costs that are less than $25,000 if it is likely total questioned costs would exceed $25,000. ? $9,129 - federal share. Recommendation We recommend MSHDA obtain and maintain sufficient documentation to support the HAF applicants' eligibility is properly determined. Management Views MSHDA agrees with the finding.
FINDING 2022-044 CCDF Cluster, ALN 93.575 and 93.596, Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Eligibility; and Matching, Level of Effort, and Earmarking - Client Eligibility See Schedule of Findings and Questioned Costs for chart/table. Condition MDE and MDHHS did not ensure compliance with federal laws and regulations relating to client eligibility for CCDF Cluster child care payments for 6 (15%) of the 40 cases we reviewed. Our review disclosed: a. MDHHS case record documentation was inconsistent with client eligibility information entered in Bridges for 3 (8%) of 40 cases reviewed. For these cases, the authorized hours of care in Bridges exceeded the client's documented need for hours of child care services. b. MDHHS did not appropriately categorize the client's eligibility based on the supporting documentation in the case record for 2 (5%) of 40 cases reviewed. We determined this did not affect the client's eligibility for child care services or level of benefits. c. MDHHS did not maintain sufficient documentation to support the client's eligibility determination for 1 (3%) of 40 cases reviewed. We noted incomplete supporting documentation related to the client's categorical eligibility. Criteria Federal regulation 45 CFR 98.20 provides eligibility requirements for child care services and permits MDE to establish eligibility requirements in addition to those outlined in the section as long as the additional requirements are not in violation of the regulation. Federal regulation 45 CFR 98.16(i)(5) requires MDE identify additional eligibility requirements in its CCDF State Plan. MDE's CCDF State Plan for Federal Fiscal Years 2022-2024 provides specific requirements for client, child, and provider eligibility. Also, CCDF program policy deems clients are either income eligible or categorically eligible if they participate in certain other programs such as Foster Care - Title IV. The client's income or categorical eligibility determines the client's level of benefits, and the child must be assigned to an eligible provider. Federal regulation 45 CFR 98.55 allows states to claim expenditures to be matched at the federal medical assistance percentage rate for allowable activities, as described in the approved state plan. In order to receive federal matching funds for a fiscal year, states must also expend an amount of nonfederal funds for child care activities in the state that is at least equal to the state's share of expenditures for the fiscal years 1994 or 1995 (whichever is greater) under Sections 402(g) and 402(i) of the federal Social Security Act as these sections were in effect before October 1, 1995, and the expenditures must be for allowable services or activities, as described in the approved state plan. Cause MDHHS informed us its internal control and monitoring activities were not sufficient to ensure MDHHS maintained or appropriately considered the required verification documentation in the client's case record to support eligibility. Effect We consider this to be a material weakness and material noncompliance because MDE may have made payments on behalf of ineligible clients and because of the overall high error rate. The federal grantor agency could issue sanctions or disallowances related to noncompliance. Known Questioned Costs Federal regulation 2 CFR 200.516(a)(3) requires the auditor to report known questioned costs that are less than $25,000 if it is likely total questioned costs would exceed $25,000. ? $1,688 - federal share. ? $707 - State share of costs that MDE inappropriately used as matching. Recommendation We recommend that MDE and MDHHS maintain sufficient documentation and ensure that Bridges appropriately reflects documentation to support client eligibility was determined in accordance with eligibility requirements. Management Views MDHHS and MDE agree with the finding.
FINDING 2022-046 CCDF Cluster, ALN 93.575 and 93.596, Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Eligibility; Matching, Level of Effort, and Earmarking; and Special Tests and Provisions - Provider Health and Safety Requirements See Schedule of Findings and Questioned Costs for chart/table. Background In accordance with the interagency agreement between MDE and the Department of Licensing and Regulatory Affairs (LARA) for fiscal year 2022, LARA was responsible for performing onsite inspections and licensing of child care providers. LARA completes on-site inspections to issue licenses, to renew licenses at the end of the license period, and to perform an interim inspection during the license period. Condition MDE and LARA did not perform timely inspections and maintain sufficient documentation to support child care providers met applicable health and safety requirements to be eligible for CCDF Cluster payments. Our review of 51 sampled licensed providers for the CCDF Cluster payments disclosed: a. LARA did not ensure timely annual on-site inspections for 7 (14%) licensed providers. We noted LARA performed the on-site inspections from 15 to 20 months after the last on-site inspection. b. LARA did not maintain documentation to support 1 renewal inspection. c. LARA did not maintain documentation to support it granted an extension when the license period had expired for 1 provider with a license renewed during fiscal year 2022. Criteria Federal regulation 45 CFR 98.41 states the lead agency (MDE) shall have in effect under State, local, or tribal law requirements designed, implemented, and enforced to protect the health and safety of children and provides the minimum health and safety topics that must include training on and be applicable to child care providers of services. The regulation also allows for MDE to include additional requirements determined to be necessary to promote child development and to protect children's health and safety as long as the additional requirements are not inconsistent with the parental choice safeguards. Federal regulation 45 CFR 98.44 requires MDE to identify in its CCDF State Plan established requirements for pre-service or orientation training in the established health and safety standards and for ongoing professional development that maintains and updates the health and safety standards described in federal regulation 45 CFR 98.41. Federal regulation 45 CFR 98.42(b)(2) states MDE shall certify in its CCDF State Plan it has monitoring policies and practices applicable to all child care providers eligible to deliver services for which assistance is provided under the CCDF Cluster. MDE must require inspections of licensed child care providers at licensure and not less than annually for compliance with all health and safety requirements described in federal regulation 45 CFR 98.41 and fire standards. Section 5 of MDE's CCDF State Plan for Federal Fiscal Years 2022-2024 provides the State's standards and monitoring processes to ensure providers meet health and safety requirements in the federal regulations. Cause LARA informed us limited resources impacted the timeliness of some inspections and the missing documentation was an oversight. Effect Child care providers may not have complied with all applicable health and safety requirements to receive CCDF Cluster funds resulting in potential improper payments to providers. The federal grantor agency could issue sanctions or disallowances related to noncompliance. Known Questioned Costs Federal regulation 2 CFR 200.516(a)(3) requires the auditor to report known questioned costs that are less than $25,000 if it is likely total questioned costs would exceed $25,000. ? $245 - federal share. ? $103 - State share of costs that MDE inappropriately used as matching. Recommendation We recommend MDE and LARA perform timely inspections and maintain sufficient documentation to support child care providers meet applicable health and safety requirements to be eligible for CCDF Cluster payments. Management Views MDE and LARA agree with the finding.
FINDING 2022-044 CCDF Cluster, ALN 93.575 and 93.596, Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Eligibility; and Matching, Level of Effort, and Earmarking - Client Eligibility See Schedule of Findings and Questioned Costs for chart/table. Condition MDE and MDHHS did not ensure compliance with federal laws and regulations relating to client eligibility for CCDF Cluster child care payments for 6 (15%) of the 40 cases we reviewed. Our review disclosed: a. MDHHS case record documentation was inconsistent with client eligibility information entered in Bridges for 3 (8%) of 40 cases reviewed. For these cases, the authorized hours of care in Bridges exceeded the client's documented need for hours of child care services. b. MDHHS did not appropriately categorize the client's eligibility based on the supporting documentation in the case record for 2 (5%) of 40 cases reviewed. We determined this did not affect the client's eligibility for child care services or level of benefits. c. MDHHS did not maintain sufficient documentation to support the client's eligibility determination for 1 (3%) of 40 cases reviewed. We noted incomplete supporting documentation related to the client's categorical eligibility. Criteria Federal regulation 45 CFR 98.20 provides eligibility requirements for child care services and permits MDE to establish eligibility requirements in addition to those outlined in the section as long as the additional requirements are not in violation of the regulation. Federal regulation 45 CFR 98.16(i)(5) requires MDE identify additional eligibility requirements in its CCDF State Plan. MDE's CCDF State Plan for Federal Fiscal Years 2022-2024 provides specific requirements for client, child, and provider eligibility. Also, CCDF program policy deems clients are either income eligible or categorically eligible if they participate in certain other programs such as Foster Care - Title IV. The client's income or categorical eligibility determines the client's level of benefits, and the child must be assigned to an eligible provider. Federal regulation 45 CFR 98.55 allows states to claim expenditures to be matched at the federal medical assistance percentage rate for allowable activities, as described in the approved state plan. In order to receive federal matching funds for a fiscal year, states must also expend an amount of nonfederal funds for child care activities in the state that is at least equal to the state's share of expenditures for the fiscal years 1994 or 1995 (whichever is greater) under Sections 402(g) and 402(i) of the federal Social Security Act as these sections were in effect before October 1, 1995, and the expenditures must be for allowable services or activities, as described in the approved state plan. Cause MDHHS informed us its internal control and monitoring activities were not sufficient to ensure MDHHS maintained or appropriately considered the required verification documentation in the client's case record to support eligibility. Effect We consider this to be a material weakness and material noncompliance because MDE may have made payments on behalf of ineligible clients and because of the overall high error rate. The federal grantor agency could issue sanctions or disallowances related to noncompliance. Known Questioned Costs Federal regulation 2 CFR 200.516(a)(3) requires the auditor to report known questioned costs that are less than $25,000 if it is likely total questioned costs would exceed $25,000. ? $1,688 - federal share. ? $707 - State share of costs that MDE inappropriately used as matching. Recommendation We recommend that MDE and MDHHS maintain sufficient documentation and ensure that Bridges appropriately reflects documentation to support client eligibility was determined in accordance with eligibility requirements. Management Views MDHHS and MDE agree with the finding.
FINDING 2022-046 CCDF Cluster, ALN 93.575 and 93.596, Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Eligibility; Matching, Level of Effort, and Earmarking; and Special Tests and Provisions - Provider Health and Safety Requirements See Schedule of Findings and Questioned Costs for chart/table. Background In accordance with the interagency agreement between MDE and the Department of Licensing and Regulatory Affairs (LARA) for fiscal year 2022, LARA was responsible for performing onsite inspections and licensing of child care providers. LARA completes on-site inspections to issue licenses, to renew licenses at the end of the license period, and to perform an interim inspection during the license period. Condition MDE and LARA did not perform timely inspections and maintain sufficient documentation to support child care providers met applicable health and safety requirements to be eligible for CCDF Cluster payments. Our review of 51 sampled licensed providers for the CCDF Cluster payments disclosed: a. LARA did not ensure timely annual on-site inspections for 7 (14%) licensed providers. We noted LARA performed the on-site inspections from 15 to 20 months after the last on-site inspection. b. LARA did not maintain documentation to support 1 renewal inspection. c. LARA did not maintain documentation to support it granted an extension when the license period had expired for 1 provider with a license renewed during fiscal year 2022. Criteria Federal regulation 45 CFR 98.41 states the lead agency (MDE) shall have in effect under State, local, or tribal law requirements designed, implemented, and enforced to protect the health and safety of children and provides the minimum health and safety topics that must include training on and be applicable to child care providers of services. The regulation also allows for MDE to include additional requirements determined to be necessary to promote child development and to protect children's health and safety as long as the additional requirements are not inconsistent with the parental choice safeguards. Federal regulation 45 CFR 98.44 requires MDE to identify in its CCDF State Plan established requirements for pre-service or orientation training in the established health and safety standards and for ongoing professional development that maintains and updates the health and safety standards described in federal regulation 45 CFR 98.41. Federal regulation 45 CFR 98.42(b)(2) states MDE shall certify in its CCDF State Plan it has monitoring policies and practices applicable to all child care providers eligible to deliver services for which assistance is provided under the CCDF Cluster. MDE must require inspections of licensed child care providers at licensure and not less than annually for compliance with all health and safety requirements described in federal regulation 45 CFR 98.41 and fire standards. Section 5 of MDE's CCDF State Plan for Federal Fiscal Years 2022-2024 provides the State's standards and monitoring processes to ensure providers meet health and safety requirements in the federal regulations. Cause LARA informed us limited resources impacted the timeliness of some inspections and the missing documentation was an oversight. Effect Child care providers may not have complied with all applicable health and safety requirements to receive CCDF Cluster funds resulting in potential improper payments to providers. The federal grantor agency could issue sanctions or disallowances related to noncompliance. Known Questioned Costs Federal regulation 2 CFR 200.516(a)(3) requires the auditor to report known questioned costs that are less than $25,000 if it is likely total questioned costs would exceed $25,000. ? $245 - federal share. ? $103 - State share of costs that MDE inappropriately used as matching. Recommendation We recommend MDE and LARA perform timely inspections and maintain sufficient documentation to support child care providers meet applicable health and safety requirements to be eligible for CCDF Cluster payments. Management Views MDE and LARA agree with the finding.
FINDING 2022-044 CCDF Cluster, ALN 93.575 and 93.596, Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Eligibility; and Matching, Level of Effort, and Earmarking - Client Eligibility See Schedule of Findings and Questioned Costs for chart/table. Condition MDE and MDHHS did not ensure compliance with federal laws and regulations relating to client eligibility for CCDF Cluster child care payments for 6 (15%) of the 40 cases we reviewed. Our review disclosed: a. MDHHS case record documentation was inconsistent with client eligibility information entered in Bridges for 3 (8%) of 40 cases reviewed. For these cases, the authorized hours of care in Bridges exceeded the client's documented need for hours of child care services. b. MDHHS did not appropriately categorize the client's eligibility based on the supporting documentation in the case record for 2 (5%) of 40 cases reviewed. We determined this did not affect the client's eligibility for child care services or level of benefits. c. MDHHS did not maintain sufficient documentation to support the client's eligibility determination for 1 (3%) of 40 cases reviewed. We noted incomplete supporting documentation related to the client's categorical eligibility. Criteria Federal regulation 45 CFR 98.20 provides eligibility requirements for child care services and permits MDE to establish eligibility requirements in addition to those outlined in the section as long as the additional requirements are not in violation of the regulation. Federal regulation 45 CFR 98.16(i)(5) requires MDE identify additional eligibility requirements in its CCDF State Plan. MDE's CCDF State Plan for Federal Fiscal Years 2022-2024 provides specific requirements for client, child, and provider eligibility. Also, CCDF program policy deems clients are either income eligible or categorically eligible if they participate in certain other programs such as Foster Care - Title IV. The client's income or categorical eligibility determines the client's level of benefits, and the child must be assigned to an eligible provider. Federal regulation 45 CFR 98.55 allows states to claim expenditures to be matched at the federal medical assistance percentage rate for allowable activities, as described in the approved state plan. In order to receive federal matching funds for a fiscal year, states must also expend an amount of nonfederal funds for child care activities in the state that is at least equal to the state's share of expenditures for the fiscal years 1994 or 1995 (whichever is greater) under Sections 402(g) and 402(i) of the federal Social Security Act as these sections were in effect before October 1, 1995, and the expenditures must be for allowable services or activities, as described in the approved state plan. Cause MDHHS informed us its internal control and monitoring activities were not sufficient to ensure MDHHS maintained or appropriately considered the required verification documentation in the client's case record to support eligibility. Effect We consider this to be a material weakness and material noncompliance because MDE may have made payments on behalf of ineligible clients and because of the overall high error rate. The federal grantor agency could issue sanctions or disallowances related to noncompliance. Known Questioned Costs Federal regulation 2 CFR 200.516(a)(3) requires the auditor to report known questioned costs that are less than $25,000 if it is likely total questioned costs would exceed $25,000. ? $1,688 - federal share. ? $707 - State share of costs that MDE inappropriately used as matching. Recommendation We recommend that MDE and MDHHS maintain sufficient documentation and ensure that Bridges appropriately reflects documentation to support client eligibility was determined in accordance with eligibility requirements. Management Views MDHHS and MDE agree with the finding.
FINDING 2022-046 CCDF Cluster, ALN 93.575 and 93.596, Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Eligibility; Matching, Level of Effort, and Earmarking; and Special Tests and Provisions - Provider Health and Safety Requirements See Schedule of Findings and Questioned Costs for chart/table. Background In accordance with the interagency agreement between MDE and the Department of Licensing and Regulatory Affairs (LARA) for fiscal year 2022, LARA was responsible for performing onsite inspections and licensing of child care providers. LARA completes on-site inspections to issue licenses, to renew licenses at the end of the license period, and to perform an interim inspection during the license period. Condition MDE and LARA did not perform timely inspections and maintain sufficient documentation to support child care providers met applicable health and safety requirements to be eligible for CCDF Cluster payments. Our review of 51 sampled licensed providers for the CCDF Cluster payments disclosed: a. LARA did not ensure timely annual on-site inspections for 7 (14%) licensed providers. We noted LARA performed the on-site inspections from 15 to 20 months after the last on-site inspection. b. LARA did not maintain documentation to support 1 renewal inspection. c. LARA did not maintain documentation to support it granted an extension when the license period had expired for 1 provider with a license renewed during fiscal year 2022. Criteria Federal regulation 45 CFR 98.41 states the lead agency (MDE) shall have in effect under State, local, or tribal law requirements designed, implemented, and enforced to protect the health and safety of children and provides the minimum health and safety topics that must include training on and be applicable to child care providers of services. The regulation also allows for MDE to include additional requirements determined to be necessary to promote child development and to protect children's health and safety as long as the additional requirements are not inconsistent with the parental choice safeguards. Federal regulation 45 CFR 98.44 requires MDE to identify in its CCDF State Plan established requirements for pre-service or orientation training in the established health and safety standards and for ongoing professional development that maintains and updates the health and safety standards described in federal regulation 45 CFR 98.41. Federal regulation 45 CFR 98.42(b)(2) states MDE shall certify in its CCDF State Plan it has monitoring policies and practices applicable to all child care providers eligible to deliver services for which assistance is provided under the CCDF Cluster. MDE must require inspections of licensed child care providers at licensure and not less than annually for compliance with all health and safety requirements described in federal regulation 45 CFR 98.41 and fire standards. Section 5 of MDE's CCDF State Plan for Federal Fiscal Years 2022-2024 provides the State's standards and monitoring processes to ensure providers meet health and safety requirements in the federal regulations. Cause LARA informed us limited resources impacted the timeliness of some inspections and the missing documentation was an oversight. Effect Child care providers may not have complied with all applicable health and safety requirements to receive CCDF Cluster funds resulting in potential improper payments to providers. The federal grantor agency could issue sanctions or disallowances related to noncompliance. Known Questioned Costs Federal regulation 2 CFR 200.516(a)(3) requires the auditor to report known questioned costs that are less than $25,000 if it is likely total questioned costs would exceed $25,000. ? $245 - federal share. ? $103 - State share of costs that MDE inappropriately used as matching. Recommendation We recommend MDE and LARA perform timely inspections and maintain sufficient documentation to support child care providers meet applicable health and safety requirements to be eligible for CCDF Cluster payments. Management Views MDE and LARA agree with the finding.
FINDING 2022-044 CCDF Cluster, ALN 93.575 and 93.596, Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Eligibility; and Matching, Level of Effort, and Earmarking - Client Eligibility See Schedule of Findings and Questioned Costs for chart/table. Condition MDE and MDHHS did not ensure compliance with federal laws and regulations relating to client eligibility for CCDF Cluster child care payments for 6 (15%) of the 40 cases we reviewed. Our review disclosed: a. MDHHS case record documentation was inconsistent with client eligibility information entered in Bridges for 3 (8%) of 40 cases reviewed. For these cases, the authorized hours of care in Bridges exceeded the client's documented need for hours of child care services. b. MDHHS did not appropriately categorize the client's eligibility based on the supporting documentation in the case record for 2 (5%) of 40 cases reviewed. We determined this did not affect the client's eligibility for child care services or level of benefits. c. MDHHS did not maintain sufficient documentation to support the client's eligibility determination for 1 (3%) of 40 cases reviewed. We noted incomplete supporting documentation related to the client's categorical eligibility. Criteria Federal regulation 45 CFR 98.20 provides eligibility requirements for child care services and permits MDE to establish eligibility requirements in addition to those outlined in the section as long as the additional requirements are not in violation of the regulation. Federal regulation 45 CFR 98.16(i)(5) requires MDE identify additional eligibility requirements in its CCDF State Plan. MDE's CCDF State Plan for Federal Fiscal Years 2022-2024 provides specific requirements for client, child, and provider eligibility. Also, CCDF program policy deems clients are either income eligible or categorically eligible if they participate in certain other programs such as Foster Care - Title IV. The client's income or categorical eligibility determines the client's level of benefits, and the child must be assigned to an eligible provider. Federal regulation 45 CFR 98.55 allows states to claim expenditures to be matched at the federal medical assistance percentage rate for allowable activities, as described in the approved state plan. In order to receive federal matching funds for a fiscal year, states must also expend an amount of nonfederal funds for child care activities in the state that is at least equal to the state's share of expenditures for the fiscal years 1994 or 1995 (whichever is greater) under Sections 402(g) and 402(i) of the federal Social Security Act as these sections were in effect before October 1, 1995, and the expenditures must be for allowable services or activities, as described in the approved state plan. Cause MDHHS informed us its internal control and monitoring activities were not sufficient to ensure MDHHS maintained or appropriately considered the required verification documentation in the client's case record to support eligibility. Effect We consider this to be a material weakness and material noncompliance because MDE may have made payments on behalf of ineligible clients and because of the overall high error rate. The federal grantor agency could issue sanctions or disallowances related to noncompliance. Known Questioned Costs Federal regulation 2 CFR 200.516(a)(3) requires the auditor to report known questioned costs that are less than $25,000 if it is likely total questioned costs would exceed $25,000. ? $1,688 - federal share. ? $707 - State share of costs that MDE inappropriately used as matching. Recommendation We recommend that MDE and MDHHS maintain sufficient documentation and ensure that Bridges appropriately reflects documentation to support client eligibility was determined in accordance with eligibility requirements. Management Views MDHHS and MDE agree with the finding.
FINDING 2022-046 CCDF Cluster, ALN 93.575 and 93.596, Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Eligibility; Matching, Level of Effort, and Earmarking; and Special Tests and Provisions - Provider Health and Safety Requirements See Schedule of Findings and Questioned Costs for chart/table. Background In accordance with the interagency agreement between MDE and the Department of Licensing and Regulatory Affairs (LARA) for fiscal year 2022, LARA was responsible for performing onsite inspections and licensing of child care providers. LARA completes on-site inspections to issue licenses, to renew licenses at the end of the license period, and to perform an interim inspection during the license period. Condition MDE and LARA did not perform timely inspections and maintain sufficient documentation to support child care providers met applicable health and safety requirements to be eligible for CCDF Cluster payments. Our review of 51 sampled licensed providers for the CCDF Cluster payments disclosed: a. LARA did not ensure timely annual on-site inspections for 7 (14%) licensed providers. We noted LARA performed the on-site inspections from 15 to 20 months after the last on-site inspection. b. LARA did not maintain documentation to support 1 renewal inspection. c. LARA did not maintain documentation to support it granted an extension when the license period had expired for 1 provider with a license renewed during fiscal year 2022. Criteria Federal regulation 45 CFR 98.41 states the lead agency (MDE) shall have in effect under State, local, or tribal law requirements designed, implemented, and enforced to protect the health and safety of children and provides the minimum health and safety topics that must include training on and be applicable to child care providers of services. The regulation also allows for MDE to include additional requirements determined to be necessary to promote child development and to protect children's health and safety as long as the additional requirements are not inconsistent with the parental choice safeguards. Federal regulation 45 CFR 98.44 requires MDE to identify in its CCDF State Plan established requirements for pre-service or orientation training in the established health and safety standards and for ongoing professional development that maintains and updates the health and safety standards described in federal regulation 45 CFR 98.41. Federal regulation 45 CFR 98.42(b)(2) states MDE shall certify in its CCDF State Plan it has monitoring policies and practices applicable to all child care providers eligible to deliver services for which assistance is provided under the CCDF Cluster. MDE must require inspections of licensed child care providers at licensure and not less than annually for compliance with all health and safety requirements described in federal regulation 45 CFR 98.41 and fire standards. Section 5 of MDE's CCDF State Plan for Federal Fiscal Years 2022-2024 provides the State's standards and monitoring processes to ensure providers meet health and safety requirements in the federal regulations. Cause LARA informed us limited resources impacted the timeliness of some inspections and the missing documentation was an oversight. Effect Child care providers may not have complied with all applicable health and safety requirements to receive CCDF Cluster funds resulting in potential improper payments to providers. The federal grantor agency could issue sanctions or disallowances related to noncompliance. Known Questioned Costs Federal regulation 2 CFR 200.516(a)(3) requires the auditor to report known questioned costs that are less than $25,000 if it is likely total questioned costs would exceed $25,000. ? $245 - federal share. ? $103 - State share of costs that MDE inappropriately used as matching. Recommendation We recommend MDE and LARA perform timely inspections and maintain sufficient documentation to support child care providers meet applicable health and safety requirements to be eligible for CCDF Cluster payments. Management Views MDE and LARA agree with the finding.
FINDING 2022-044 CCDF Cluster, ALN 93.575 and 93.596, Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Eligibility; and Matching, Level of Effort, and Earmarking - Client Eligibility See Schedule of Findings and Questioned Costs for chart/table. Condition MDE and MDHHS did not ensure compliance with federal laws and regulations relating to client eligibility for CCDF Cluster child care payments for 6 (15%) of the 40 cases we reviewed. Our review disclosed: a. MDHHS case record documentation was inconsistent with client eligibility information entered in Bridges for 3 (8%) of 40 cases reviewed. For these cases, the authorized hours of care in Bridges exceeded the client's documented need for hours of child care services. b. MDHHS did not appropriately categorize the client's eligibility based on the supporting documentation in the case record for 2 (5%) of 40 cases reviewed. We determined this did not affect the client's eligibility for child care services or level of benefits. c. MDHHS did not maintain sufficient documentation to support the client's eligibility determination for 1 (3%) of 40 cases reviewed. We noted incomplete supporting documentation related to the client's categorical eligibility. Criteria Federal regulation 45 CFR 98.20 provides eligibility requirements for child care services and permits MDE to establish eligibility requirements in addition to those outlined in the section as long as the additional requirements are not in violation of the regulation. Federal regulation 45 CFR 98.16(i)(5) requires MDE identify additional eligibility requirements in its CCDF State Plan. MDE's CCDF State Plan for Federal Fiscal Years 2022-2024 provides specific requirements for client, child, and provider eligibility. Also, CCDF program policy deems clients are either income eligible or categorically eligible if they participate in certain other programs such as Foster Care - Title IV. The client's income or categorical eligibility determines the client's level of benefits, and the child must be assigned to an eligible provider. Federal regulation 45 CFR 98.55 allows states to claim expenditures to be matched at the federal medical assistance percentage rate for allowable activities, as described in the approved state plan. In order to receive federal matching funds for a fiscal year, states must also expend an amount of nonfederal funds for child care activities in the state that is at least equal to the state's share of expenditures for the fiscal years 1994 or 1995 (whichever is greater) under Sections 402(g) and 402(i) of the federal Social Security Act as these sections were in effect before October 1, 1995, and the expenditures must be for allowable services or activities, as described in the approved state plan. Cause MDHHS informed us its internal control and monitoring activities were not sufficient to ensure MDHHS maintained or appropriately considered the required verification documentation in the client's case record to support eligibility. Effect We consider this to be a material weakness and material noncompliance because MDE may have made payments on behalf of ineligible clients and because of the overall high error rate. The federal grantor agency could issue sanctions or disallowances related to noncompliance. Known Questioned Costs Federal regulation 2 CFR 200.516(a)(3) requires the auditor to report known questioned costs that are less than $25,000 if it is likely total questioned costs would exceed $25,000. ? $1,688 - federal share. ? $707 - State share of costs that MDE inappropriately used as matching. Recommendation We recommend that MDE and MDHHS maintain sufficient documentation and ensure that Bridges appropriately reflects documentation to support client eligibility was determined in accordance with eligibility requirements. Management Views MDHHS and MDE agree with the finding.
FINDING 2022-046 CCDF Cluster, ALN 93.575 and 93.596, Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Eligibility; Matching, Level of Effort, and Earmarking; and Special Tests and Provisions - Provider Health and Safety Requirements See Schedule of Findings and Questioned Costs for chart/table. Background In accordance with the interagency agreement between MDE and the Department of Licensing and Regulatory Affairs (LARA) for fiscal year 2022, LARA was responsible for performing onsite inspections and licensing of child care providers. LARA completes on-site inspections to issue licenses, to renew licenses at the end of the license period, and to perform an interim inspection during the license period. Condition MDE and LARA did not perform timely inspections and maintain sufficient documentation to support child care providers met applicable health and safety requirements to be eligible for CCDF Cluster payments. Our review of 51 sampled licensed providers for the CCDF Cluster payments disclosed: a. LARA did not ensure timely annual on-site inspections for 7 (14%) licensed providers. We noted LARA performed the on-site inspections from 15 to 20 months after the last on-site inspection. b. LARA did not maintain documentation to support 1 renewal inspection. c. LARA did not maintain documentation to support it granted an extension when the license period had expired for 1 provider with a license renewed during fiscal year 2022. Criteria Federal regulation 45 CFR 98.41 states the lead agency (MDE) shall have in effect under State, local, or tribal law requirements designed, implemented, and enforced to protect the health and safety of children and provides the minimum health and safety topics that must include training on and be applicable to child care providers of services. The regulation also allows for MDE to include additional requirements determined to be necessary to promote child development and to protect children's health and safety as long as the additional requirements are not inconsistent with the parental choice safeguards. Federal regulation 45 CFR 98.44 requires MDE to identify in its CCDF State Plan established requirements for pre-service or orientation training in the established health and safety standards and for ongoing professional development that maintains and updates the health and safety standards described in federal regulation 45 CFR 98.41. Federal regulation 45 CFR 98.42(b)(2) states MDE shall certify in its CCDF State Plan it has monitoring policies and practices applicable to all child care providers eligible to deliver services for which assistance is provided under the CCDF Cluster. MDE must require inspections of licensed child care providers at licensure and not less than annually for compliance with all health and safety requirements described in federal regulation 45 CFR 98.41 and fire standards. Section 5 of MDE's CCDF State Plan for Federal Fiscal Years 2022-2024 provides the State's standards and monitoring processes to ensure providers meet health and safety requirements in the federal regulations. Cause LARA informed us limited resources impacted the timeliness of some inspections and the missing documentation was an oversight. Effect Child care providers may not have complied with all applicable health and safety requirements to receive CCDF Cluster funds resulting in potential improper payments to providers. The federal grantor agency could issue sanctions or disallowances related to noncompliance. Known Questioned Costs Federal regulation 2 CFR 200.516(a)(3) requires the auditor to report known questioned costs that are less than $25,000 if it is likely total questioned costs would exceed $25,000. ? $245 - federal share. ? $103 - State share of costs that MDE inappropriately used as matching. Recommendation We recommend MDE and LARA perform timely inspections and maintain sufficient documentation to support child care providers meet applicable health and safety requirements to be eligible for CCDF Cluster payments. Management Views MDE and LARA agree with the finding.