Finding Number: 2024-004 Repeat Finding: Similar to prior year finding 2023-005 Program Name/Assistance Listing Title: Indian School Equalization Program, Administrative Cost Grants for Indian Schools, Indian Education Facilities, Operations, and Maintenance, Special Education Cluster, and Education Stabilization Fund - COVID-19 Assistance Listing Number: 15.042, 15.046, 15.047, 84.010, 84.027, and 84.425D Federal Agency: U.S. Department of the Interior, U.S. Department of Treasury, U.S. Department of Education Federal Award Number: A23AV00811, Unknown (21.027) Questioned Costs: None Type of Finding: Noncompliance, Material Weakness Compliance Requirement: Reporting Criteria: 2 CFR § 200.512(a) provides, in part: "The audit must be completed and the data collection form ... must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period." 2 CFR § 200.520 provides, in part: "That to qualify as a low-risk auditee and be eligible for reduced audit coverage the following condition must be met: Single audits were performed on an annual basis in accordance with the provisions of this Subpart, including submitting the data collection form and the reporting package to the FAC within the timeframe specified in § 200.512." Condition: The School did submit their audit for the fiscal year ending June 30, 2024 timely. The audit was submitted August XX, 2025, which was XXX days past the March 31, 2025 deadline. Effect: Not making all audit documentation available in a timely manner resulted in the audit and data collection form submissions to be late and, therefore, not available to the public within the required timeframe. This late submission also excludes the School from qualifying as a low-risk auditee. Cause: Management oversight. Recommendation: The School should implement procedures to ensure that all audit documentation is available for the audit in a timely manner and the audit report is completed and submitted within the appropriate timeframe. Response: The School’s responses are presented in a separate document. Contact person: Dolores Silva, Chief Financial Officer
Finding Number: 2024-004 Repeat Finding: Similar to prior year finding 2023-005 Program Name/Assistance Listing Title: Indian School Equalization Program, Administrative Cost Grants for Indian Schools, Indian Education Facilities, Operations, and Maintenance, Special Education Cluster, and Education Stabilization Fund - COVID-19 Assistance Listing Number: 15.042, 15.046, 15.047, 84.010, 84.027, and 84.425D Federal Agency: U.S. Department of the Interior, U.S. Department of Treasury, U.S. Department of Education Federal Award Number: A23AV00811, Unknown (21.027) Questioned Costs: None Type of Finding: Noncompliance, Material Weakness Compliance Requirement: Reporting Criteria: 2 CFR § 200.512(a) provides, in part: "The audit must be completed and the data collection form ... must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period." 2 CFR § 200.520 provides, in part: "That to qualify as a low-risk auditee and be eligible for reduced audit coverage the following condition must be met: Single audits were performed on an annual basis in accordance with the provisions of this Subpart, including submitting the data collection form and the reporting package to the FAC within the timeframe specified in § 200.512." Condition: The School did submit their audit for the fiscal year ending June 30, 2024 timely. The audit was submitted August XX, 2025, which was XXX days past the March 31, 2025 deadline. Effect: Not making all audit documentation available in a timely manner resulted in the audit and data collection form submissions to be late and, therefore, not available to the public within the required timeframe. This late submission also excludes the School from qualifying as a low-risk auditee. Cause: Management oversight. Recommendation: The School should implement procedures to ensure that all audit documentation is available for the audit in a timely manner and the audit report is completed and submitted within the appropriate timeframe. Response: The School’s responses are presented in a separate document. Contact person: Dolores Silva, Chief Financial Officer
Finding Number: 2024-004 Repeat Finding: Similar to prior year finding 2023-005 Program Name/Assistance Listing Title: Indian School Equalization Program, Administrative Cost Grants for Indian Schools, Indian Education Facilities, Operations, and Maintenance, Special Education Cluster, and Education Stabilization Fund - COVID-19 Assistance Listing Number: 15.042, 15.046, 15.047, 84.010, 84.027, and 84.425D Federal Agency: U.S. Department of the Interior, U.S. Department of Treasury, U.S. Department of Education Federal Award Number: A23AV00811, Unknown (21.027) Questioned Costs: None Type of Finding: Noncompliance, Material Weakness Compliance Requirement: Reporting Criteria: 2 CFR § 200.512(a) provides, in part: "The audit must be completed and the data collection form ... must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period." 2 CFR § 200.520 provides, in part: "That to qualify as a low-risk auditee and be eligible for reduced audit coverage the following condition must be met: Single audits were performed on an annual basis in accordance with the provisions of this Subpart, including submitting the data collection form and the reporting package to the FAC within the timeframe specified in § 200.512." Condition: The School did submit their audit for the fiscal year ending June 30, 2024 timely. The audit was submitted August XX, 2025, which was XXX days past the March 31, 2025 deadline. Effect: Not making all audit documentation available in a timely manner resulted in the audit and data collection form submissions to be late and, therefore, not available to the public within the required timeframe. This late submission also excludes the School from qualifying as a low-risk auditee. Cause: Management oversight. Recommendation: The School should implement procedures to ensure that all audit documentation is available for the audit in a timely manner and the audit report is completed and submitted within the appropriate timeframe. Response: The School’s responses are presented in a separate document. Contact person: Dolores Silva, Chief Financial Officer
Submission of the Audit Package and Data Collection Form - Federal Agency: Various Assistance Listing Number: Multiple Compliance Requirement: Reporting Criteria: Per 2 CFR §200.510(b), the auditee must prepare a Schedule of Federal Awards (SEFA) for the period covered by the auditee’s financial statements. Per §200.512(a), the SEFA must be submitted to the Federal Audit Clearinghouse (FAC) within the required deadline. Condition: The audit reporting package and data collection form for the year ended June 30, 2024, was not submitted to the FAC within the timeframe as required by the Uniform Guidance. Cause: The delay was due to identified discrepancies and inconsistencies in the initial financial statement reconciliations which the Organization subsequently prepared revised reconciliations, made material adjustments to affected accounts, and issued an updated trial balance. This caused a significant delay in the audit testing and wrap up. Effect: To qualify as a low-risk auditee, 2 CFR section 200.520 requires the audit reporting package and data collection form to be submitted to the FAC by the due date for each of the previous two years. Late filing will result in noncompliance with timely submission of financial information to the grantor agencies. Recommendation: We recommend the Organization strengthen its internal controls over the reconciliation process, including implementing a formal review procedure and ensuring reconciliations are supported by complete and accurate documentation prior to audit fieldwork. Timely and accurate reconciliations are critical to maintaining reliable financial reporting and audit readiness. Questioned costs: None Responsible Official's Response: CMJTS acknowledges the delay and has been making improvements to ensure reconciliations are done timely. Accounting staff have been given additional training on bank reconciliations, and they are now reconciling bank transactions daily. This real time reconciling helps ensure that all transactions are processed accurately. Bank reconciliations are then signed off by Finance Manager and the Board Treasurer monthly. Accounting staff have been given additional training on statement of financial position reconciliations and will be reconciling them monthly. The statement of financial position, with supporting documentation, will then be signed off by the Finance Manager monthly.
Finding Number: 2024-004 Repeat Finding: Yes, prior year finding 2023-004. Program Name/Assistance Listing Title: Indian School Equalization Program Assistance Listing Number: 15.042 Federal Agency: U.S. Department of the Interior Federal Award Number: A23AV00827 Questioned Costs: None Type of Finding: Noncompliance, Material Weakness Compliance Requirement: L. Reporting Criteria: 2 CFR § 200.512(a) provides, in part: "The audit must be completed and the data collection form ... must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period." 2 CFR § 200.520 provides, in part: "That to qualify as a low-risk auditee and be eligible for reduced audit coverage the following condition must be met: Single audits were performed on an annual basis in accordance with the provisions of this Subpart, including submitting the data collection form and the reporting package to the FAC within the timeframe specified in § 200.512." Condition: The School did submit their audit for the fiscal year ending June 30, 2024 timely. The audit was submitted May 1, 2026, which was 396 days past the March 31, 2025 deadline. Effect: Not making all audit documentation available in a timely manner resulted in the audit and data collection form submissions to be late and, therefore, not available to the public within the required timeframe. This late submission also excludes the School from qualifying as a low-risk auditee. Cause: Management did not provide the trial balance until 14 months after the end of the fiscal year and five months after the federal reporting deadline. Throughout the audit process, management continuously refused to provide the requested information for the expenditure testing related to federal programs. Recommendation: The School should implement procedures to ensure that all audit documentation is available for the audit in a timely manner and the audit report is completed and submitted within the appropriate timeframe. View of Responsible Official: The School’s corrective action plan presented in a separate document includes the views and planned corrective action of its responsible officials. We are not required to and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy.
2024-008 Single Audit Reporting Deadline Federal Agency: All federal agencies Federal Program: All major federal programs Compliance Requirements: Reporting - Single Audit Submission Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria: The Uniform Guidance, 2 CFR Section 200.512(a)(1), requires the single audit to be completed and the data collection form and reporting package to be submitted to the Federal Audit Clearinghouse within the earlier of 30 calendar days after receipt of the auditor's reports(s) or nine months after the end of the audit period. Condition: The County did not submit its single audit reporting package and data collection form for the fiscal year ended June 30, 2024 by the required deadline. Cause: Delays in closing the County's accounting records and preparing year-end financial information, including the matters described in findings 2024-004 and 2024-005, prevented the single audit from being completed and submitted timely. Effect: The County is not in compliance with the reporting requirements of the Uniform Guidance. Late submission prevents the County from qualifying as a low-risk auditee under 2 CFR Section 200.520 and may result in federal awarding agencies taking action under 2 CFR Section 200.505. Questioned Costs: None. Context: The single audit reporting package and data collection form for the fiscal year ended June 30, 2024 were due March 31, 2025, and were not submitted by that date. Recommendation: We recommend that the County establish a year-end closing schedule with defined deadlines for reconciling accounts and preparing financial information, so that the single audit can be completed and the reporting package and data collection form submitted within the time frame required by the Uniform Guidance. Views of Responsible Officials: Please see the last page of this report for the response to this finding.
Single Audit Data Collection Form Not Filed by Due Date- Condition: The data collection form for the Single Audit ended May 31, 2023 was not submitted to the Federal Clearinghouse by Feburary 28, 2024.Criteria" 2 CRF Section 200.512(b) provides for a form, referred to as the data collection form, to be prepared at the completion of each audit and submitted by the auditee to the Federal Audit Clearinghouse the earlier of 30 calendar days after the receipt of the auditor's report or nine months after the end of the audit period. Cause: THe audit report was not issued prior to February 28, 2024, submission date requirement. Therefore, the data collection form required at audit completion was not filed by this date. Effect: The Organization has not met the reporting requirements related to timely submission of the data collection from required for a Single Audit. Therefore, per 2 CFR section 200.520, the Organization will not meet the low-risk auditee criteria for the next Single Audit the requires sbumission of the data collection form and reporting package. Recommendation: We recommend that the Organization develop specific procedures to ensure that the data collection for is submitted prior to the February 28th reporting deadline. Response: The Organization will work with the audit firm to ensure the data collection form is filed timely.
Single Audit Data Collection Form Not Filed by Due Date- Condition: The data collection form for the Single Audit ended May 31, 2023 was not submitted to the Federal Clearinghouse by Feburary 28, 2024.Criteria" 2 CRF Section 200.512(b) provides for a form, referred to as the data collection form, to be prepared at the completion of each audit and submitted by the auditee to the Federal Audit Clearinghouse the earlier of 30 calendar days after the receipt of the auditor's report or nine months after the end of the audit period. Cause: THe audit report was not issued prior to February 28, 2024, submission date requirement. Therefore, the data collection form required at audit completion was not filed by this date. Effect: The Organization has not met the reporting requirements related to timely submission of the data collection from required for a Single Audit. Therefore, per 2 CFR section 200.520, the Organization will not meet the low-risk auditee criteria for the next Single Audit the requires sbumission of the data collection form and reporting package. Recommendation: We recommend that the Organization develop specific procedures to ensure that the data collection for is submitted prior to the February 28th reporting deadline. Response: The Organization will work with the audit firm to ensure the data collection form is filed timely.
Finding Number: 2024-002 Finding Type: Noncompliance Information on the Federal Program: N/A – Not program-specific Criteria: 2 CFR Section 200.512(a) requires the reporting package and data collection form to be submitted to the Federal Audit Clearinghouse (FAC) the earlier of 30 calendar days after the reports are received from the auditor or nine months after the end of the audit period. Condition: FAC filing for fiscal year ended March 31, 2024 was submitted late. Cause: The Organization did not have effective internal controls to ensure timely and accurate preparation of financial information, including account reconciliations (see Finding 2024.001). As a result, management did not have the information necessary to complete the FAC filing within the timeframe required by 2 CFR §200.520(a). Effect: The late submission of the Single Audit report to the Federal Audit Clearinghouse creates noncompliance with federal reporting requirements and increases the Organization’s risk of administrative actions by federal awarding agencies, including Health Resources and Services Administration (HRSA). This may result in delayed acceptance of federal awards, imposition of grant conditions, or restrictions on access to federal funds until the report is submitted and accepted. Questioned Costs: None Repeat Finding: Yes, 2023-002 Recommendation: The Organization should implement procedures to ensure that account reconciliations and financial reporting are completed in a timely manner, enabling the Single Audit reporting package to be submitted to the Federal Audit Clearinghouse within the required timeframe. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding. The Organization is implementing procedures to complete and review account reconciliations and financial reporting on a monthly basis, with appropriate oversight and staffing. These steps are intended to ensure that future Single Audit reporting packages are submitted to the Federal Audit Clearinghouse within the required timeframe.
Program: CFDA #93.224 - Consolidated Health Centers, CFDA #93.527 - Grants for New and Expanded Services under the Health Center Program. Condition: For the second consecutive years, BRHC did not comply with the required submission date of the data collection form and reporting package to the Federal Audit Clearinghouse (FAC) for the year ended December 31, 2023. Criteria: The Uniform Guidance in 2 CFR section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the FAC within the earlier of 30 days after receipt of the auditor's report or nine (9) months after year end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Cause: The audit report was not issued prior to the September 30, 2023, submission date requirement. Therefore, the data collection form required at audit completion was not filed by this date. Effect: BRHC has not met the reporting requirements related to timely submission of the data collection form required for a Single Audit. Therefore, per 2 CFR section 200.520, BRHC will not meet the low-risk auditee criteria for future Single Audits that requires submission of the data collection form and reporting package by the due date for each of the two proceeding audit years. Recommendation: We recommend that BRHC develop specific procedures to ensure that the audit report is received prior to the September 30 reporting deadline. View of Responsible Officials and Planned Corrective Action: See Corrective Action Plan.
Program: CFDA #93.224 - Consolidated Health Centers, CFDA #93.527 - Grants for New and Expanded Services under the Health Center Program. Condition: For the second consecutive years, BRHC did not comply with the required submission date of the data collection form and reporting package to the Federal Audit Clearinghouse (FAC) for the year ended December 31, 2023. Criteria: The Uniform Guidance in 2 CFR section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the FAC within the earlier of 30 days after receipt of the auditor's report or nine (9) months after year end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Cause: The audit report was not issued prior to the September 30, 2023, submission date requirement. Therefore, the data collection form required at audit completion was not filed by this date. Effect: BRHC has not met the reporting requirements related to timely submission of the data collection form required for a Single Audit. Therefore, per 2 CFR section 200.520, BRHC will not meet the low-risk auditee criteria for future Single Audits that requires submission of the data collection form and reporting package by the due date for each of the two proceeding audit years. Recommendation: We recommend that BRHC develop specific procedures to ensure that the audit report is received prior to the September 30 reporting deadline. View of Responsible Officials and Planned Corrective Action: See Corrective Action Plan.
Program: CFDA #93.224 - Consolidated Health Centers, CFDA #93.527 - Grants for New and Expanded Services under the Health Center Program. Condition: For the second consecutive years, BRHC did not comply with the required submission date of the data collection form and reporting package to the Federal Audit Clearinghouse (FAC) for the year ended December 31, 2023. Criteria: The Uniform Guidance in 2 CFR section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the FAC within the earlier of 30 days after receipt of the auditor's report or nine (9) months after year end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Cause: The audit report was not issued prior to the September 30, 2023, submission date requirement. Therefore, the data collection form required at audit completion was not filed by this date. Effect: BRHC has not met the reporting requirements related to timely submission of the data collection form required for a Single Audit. Therefore, per 2 CFR section 200.520, BRHC will not meet the low-risk auditee criteria for future Single Audits that requires submission of the data collection form and reporting package by the due date for each of the two proceeding audit years. Recommendation: We recommend that BRHC develop specific procedures to ensure that the audit report is received prior to the September 30 reporting deadline. View of Responsible Officials and Planned Corrective Action: See Corrective Action Plan.
Program: CFDA #93.224 - Consolidated Health Centers, CFDA #93.527 - Grants for New and Expanded Services under the Health Center Program. Condition: For the second consecutive years, BRHC did not comply with the required submission date of the data collection form and reporting package to the Federal Audit Clearinghouse (FAC) for the year ended December 31, 2023. Criteria: The Uniform Guidance in 2 CFR section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the FAC within the earlier of 30 days after receipt of the auditor's report or nine (9) months after year end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Cause: The audit report was not issued prior to the September 30, 2023, submission date requirement. Therefore, the data collection form required at audit completion was not filed by this date. Effect: BRHC has not met the reporting requirements related to timely submission of the data collection form required for a Single Audit. Therefore, per 2 CFR section 200.520, BRHC will not meet the low-risk auditee criteria for future Single Audits that requires submission of the data collection form and reporting package by the due date for each of the two proceeding audit years. Recommendation: We recommend that BRHC develop specific procedures to ensure that the audit report is received prior to the September 30 reporting deadline. View of Responsible Officials and Planned Corrective Action: See Corrective Action Plan.
Program: CFDA #93.224 - Consolidated Health Centers, CFDA #93.527 - Grants for New and Expanded Services under the Health Center Program. Condition: For the second consecutive years, BRHC did not comply with the required submission date of the data collection form and reporting package to the Federal Audit Clearinghouse (FAC) for the year ended December 31, 2023. Criteria: The Uniform Guidance in 2 CFR section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the FAC within the earlier of 30 days after receipt of the auditor's report or nine (9) months after year end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Cause: The audit report was not issued prior to the September 30, 2023, submission date requirement. Therefore, the data collection form required at audit completion was not filed by this date. Effect: BRHC has not met the reporting requirements related to timely submission of the data collection form required for a Single Audit. Therefore, per 2 CFR section 200.520, BRHC will not meet the low-risk auditee criteria for future Single Audits that requires submission of the data collection form and reporting package by the due date for each of the two proceeding audit years. Recommendation: We recommend that BRHC develop specific procedures to ensure that the audit report is received prior to the September 30 reporting deadline. View of Responsible Officials and Planned Corrective Action: See Corrective Action Plan.
Program: CFDA #93.224 - Consolidated Health Centers, CFDA #93.527 - Grants for New and Expanded Services under the Health Center Program. Condition: For the second consecutive years, BRHC did not comply with the required submission date of the data collection form and reporting package to the Federal Audit Clearinghouse (FAC) for the year ended December 31, 2023. Criteria: The Uniform Guidance in 2 CFR section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the FAC within the earlier of 30 days after receipt of the auditor's report or nine (9) months after year end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Cause: The audit report was not issued prior to the September 30, 2023, submission date requirement. Therefore, the data collection form required at audit completion was not filed by this date. Effect: BRHC has not met the reporting requirements related to timely submission of the data collection form required for a Single Audit. Therefore, per 2 CFR section 200.520, BRHC will not meet the low-risk auditee criteria for future Single Audits that requires submission of the data collection form and reporting package by the due date for each of the two proceeding audit years. Recommendation: We recommend that BRHC develop specific procedures to ensure that the audit report is received prior to the September 30 reporting deadline. View of Responsible Officials and Planned Corrective Action: See Corrective Action Plan.
Program: CFDA #93.224 - Consolidated Health Centers, CFDA #93.527 - Grants for New and Expanded Services under the Health Center Program. Condition: For the second consecutive years, BRHC did not comply with the required submission date of the data collection form and reporting package to the Federal Audit Clearinghouse (FAC) for the year ended December 31, 2023. Criteria: The Uniform Guidance in 2 CFR section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the FAC within the earlier of 30 days after receipt of the auditor's report or nine (9) months after year end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Cause: The audit report was not issued prior to the September 30, 2023, submission date requirement. Therefore, the data collection form required at audit completion was not filed by this date. Effect: BRHC has not met the reporting requirements related to timely submission of the data collection form required for a Single Audit. Therefore, per 2 CFR section 200.520, BRHC will not meet the low-risk auditee criteria for future Single Audits that requires submission of the data collection form and reporting package by the due date for each of the two proceeding audit years. Recommendation: We recommend that BRHC develop specific procedures to ensure that the audit report is received prior to the September 30 reporting deadline. View of Responsible Officials and Planned Corrective Action: See Corrective Action Plan.
Program: CFDA #93.224 - Consolidated Health Centers, CFDA #93.527 - Grants for New and Expanded Services under the Health Center Program. Condition: For the second consecutive years, BRHC did not comply with the required submission date of the data collection form and reporting package to the Federal Audit Clearinghouse (FAC) for the year ended December 31, 2023. Criteria: The Uniform Guidance in 2 CFR section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the FAC within the earlier of 30 days after receipt of the auditor's report or nine (9) months after year end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Cause: The audit report was not issued prior to the September 30, 2023, submission date requirement. Therefore, the data collection form required at audit completion was not filed by this date. Effect: BRHC has not met the reporting requirements related to timely submission of the data collection form required for a Single Audit. Therefore, per 2 CFR section 200.520, BRHC will not meet the low-risk auditee criteria for future Single Audits that requires submission of the data collection form and reporting package by the due date for each of the two proceeding audit years. Recommendation: We recommend that BRHC develop specific procedures to ensure that the audit report is received prior to the September 30 reporting deadline. View of Responsible Officials and Planned Corrective Action: See Corrective Action Plan.
Program: CFDA #93.224 - Consolidated Health Centers, CFDA #93.527 - Grants for New and Expanded Services under the Health Center Program. Condition: For the second consecutive years, BRHC did not comply with the required submission date of the data collection form and reporting package to the Federal Audit Clearinghouse (FAC) for the year ended December 31, 2023. Criteria: The Uniform Guidance in 2 CFR section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the FAC within the earlier of 30 days after receipt of the auditor's report or nine (9) months after year end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Cause: The audit report was not issued prior to the September 30, 2023, submission date requirement. Therefore, the data collection form required at audit completion was not filed by this date. Effect: BRHC has not met the reporting requirements related to timely submission of the data collection form required for a Single Audit. Therefore, per 2 CFR section 200.520, BRHC will not meet the low-risk auditee criteria for future Single Audits that requires submission of the data collection form and reporting package by the due date for each of the two proceeding audit years. Recommendation: We recommend that BRHC develop specific procedures to ensure that the audit report is received prior to the September 30 reporting deadline. View of Responsible Officials and Planned Corrective Action: See Corrective Action Plan.
Program: CFDA #93.224 - Consolidated Health Centers, CFDA #93.527 - Grants for New and Expanded Services under the Health Center Program. Condition: For the second consecutive years, BRHC did not comply with the required submission date of the data collection form and reporting package to the Federal Audit Clearinghouse (FAC) for the year ended December 31, 2023. Criteria: The Uniform Guidance in 2 CFR section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the FAC within the earlier of 30 days after receipt of the auditor's report or nine (9) months after year end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Cause: The audit report was not issued prior to the September 30, 2023, submission date requirement. Therefore, the data collection form required at audit completion was not filed by this date. Effect: BRHC has not met the reporting requirements related to timely submission of the data collection form required for a Single Audit. Therefore, per 2 CFR section 200.520, BRHC will not meet the low-risk auditee criteria for future Single Audits that requires submission of the data collection form and reporting package by the due date for each of the two proceeding audit years. Recommendation: We recommend that BRHC develop specific procedures to ensure that the audit report is received prior to the September 30 reporting deadline. View of Responsible Officials and Planned Corrective Action: See Corrective Action Plan.
Program: CFDA #93.224 - Consolidated Health Centers, CFDA #93.527 - Grants for New and Expanded Services under the Health Center Program. Condition: For the second consecutive years, BRHC did not comply with the required submission date of the data collection form and reporting package to the Federal Audit Clearinghouse (FAC) for the year ended December 31, 2023. Criteria: The Uniform Guidance in 2 CFR section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the FAC within the earlier of 30 days after receipt of the auditor's report or nine (9) months after year end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Cause: The audit report was not issued prior to the September 30, 2023, submission date requirement. Therefore, the data collection form required at audit completion was not filed by this date. Effect: BRHC has not met the reporting requirements related to timely submission of the data collection form required for a Single Audit. Therefore, per 2 CFR section 200.520, BRHC will not meet the low-risk auditee criteria for future Single Audits that requires submission of the data collection form and reporting package by the due date for each of the two proceeding audit years. Recommendation: We recommend that BRHC develop specific procedures to ensure that the audit report is received prior to the September 30 reporting deadline. View of Responsible Officials and Planned Corrective Action: See Corrective Action Plan.
Program: CFDA #93.224 - Consolidated Health Centers, CFDA #93.527 - Grants for New and Expanded Services under the Health Center Program. Condition: For the second consecutive years, BRHC did not comply with the required submission date of the data collection form and reporting package to the Federal Audit Clearinghouse (FAC) for the year ended December 31, 2023. Criteria: The Uniform Guidance in 2 CFR section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the FAC within the earlier of 30 days after receipt of the auditor's report or nine (9) months after year end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Cause: The audit report was not issued prior to the September 30, 2023, submission date requirement. Therefore, the data collection form required at audit completion was not filed by this date. Effect: BRHC has not met the reporting requirements related to timely submission of the data collection form required for a Single Audit. Therefore, per 2 CFR section 200.520, BRHC will not meet the low-risk auditee criteria for future Single Audits that requires submission of the data collection form and reporting package by the due date for each of the two proceeding audit years. Recommendation: We recommend that BRHC develop specific procedures to ensure that the audit report is received prior to the September 30 reporting deadline. View of Responsible Officials and Planned Corrective Action: See Corrective Action Plan.
Compliance with Reporting Under the Uniform Guidance Information on Federal Program: U.S. Department of Housing and Urban Development Assistance Listing No. 14.871 and Coronavirus State and Local Fiscal Recovery Funds Assistance Listing No. 21.027. Criteria: According to the code of federal regulations section § 200.520 (a), single audits must be performed on an annual basis, including submitting the data collection form and the reporting package to the FAC within the timeframe specified in §200.512 which is the earlier of 30 calendar days after receipt of the auditor’s report or nine months after the end of the audit period. Statement of Condition: The data collection forms for the years 2019 through 2021 have not been submitted timely. Statement of Cause: Due to significant turnover in key positions within the Town’s fiscal office, the financial audits are currently behind. The results of the financial audits are required as part of the submission with the data collection form to the FAC, therefore, the data collection forms cannot be completed and submitted until the completion of the financial audits. Statement of Effect: The Town was not in compliance with federal guidelines. Questioned Cost: None. Repeat Finding: Yes. Perspective Information: As part of testing the compliance with the Uniform Guidance, the dates of the submissions to the FAC are reviewed. Recommendation: The Town should follow federal guidelines by submitting the data collection form to the FAC in a timely manner. Views of responsible officials and Planned Corrective Actions: The Town of Guilderland Comptroller’s Office suffered significant turnover in key positions during the fiscal years of 2019 and 2021 including the retirement of the Town Comptroller and Fiscal Officer. In addition, the COVID-19 pandemic had significant impact to the Town, particularly during 2020 when remote work was encouraged. This combination and sequence of events made it impossible to meet the required external audit reporting deadlines. Since these events, the Town has filled the vacant positions and has scheduled all remaining audits. The auditors are working as expeditiously as possible to complete the remaining audits. The required reporting noted in the guidelines above cannot be completed until each prior year audit is finished, therefore causing a delay in each fiscal year’s reporting.
2023-005 – FAILURE TO COMPLETE THE SINGLE AUDIT TIMELY AND TO SUBMIT THE REQUIRED REPORTING PACKAGE TO THE FEDERAL AUDIT CLEARINGHOUSE Federal Program: Not applicable. Type of Finding: Significant deficiency in internal control over compliance; noncompliance. Repeat finding – reported in the prior year as finding 2022-004. Criteria: 2 CFR 200.501(a) requires a non-Federal entity that expends $750,000 or more in Federal awards during its fiscal year to have a single or program-specific audit conducted for that year. 2 CFR 200.512(a) requires the audit to be completed and the reporting package and data collection form (Form SF-SAC) to be submitted within the earlier of 30 calendar days after receipt of the auditor's reports or nine months after the end of the audit period, and 2 CFR 200.512(b) requires the auditee to electronically submit the data collection form and reporting package to the Federal Audit Clearinghouse. The Institute's grant agreements also require that an annual audit be performed. Condition: The audits of the Institute for the years ended December 31, 2022, 2023, and 2024 were not completed, and the reporting packages and data collection forms were not submitted to the Federal Audit Clearinghouse within the periods required by 2 CFR 200.512. Cause: The Institute has not established or implemented written policies, procedures, and related internal controls sufficient to ensure that the annual Single Audit is completed and that the reporting package and data collection form are submitted to the Federal Audit Clearinghouse by the required due date. Responsibility for monitoring these deadlines has not been assigned to specific personnel. Effect: The Institute did not comply with the audit and reporting requirements of the Uniform Guidance. Late submission of the reporting package may cause Federal awarding agencies and pass-through entities to impose additional award conditions or other remedies for noncompliance under 2 CFR 200.208 and 2 CFR 200.339, and precludes the Institute from qualifying as a low-risk auditee under 2 CFR 200.520. Questioned Costs: None Recommendation: The Institute should adopt written policies and procedures that assign responsibility for engaging the auditor, completing the annual Single Audit, and submitting the reporting package and data collection form to the Federal Audit Clearinghouse within nine months after each fiscal year end, and should maintain a compliance calendar to monitor those deadlines. Management's Views and Response: The Institute has engaged an auditor to complete the December 31, 2022, 2023, 2024, and 2025 Single Audits concurrently, and will submit each reporting package and data collection form to the Federal Audit Clearinghouse as each audit is completed. Thereafter, the Institute will complete the audit and submit the reporting package within nine months after year end.
U.S. Department of Health and Human Services Pass-Through Minnesota Department of Commerce ALN 93.568 Low-Income Home Energy Assistance U.S. Department of Health and Human Services Direct ALN 93.600 Head Start Cluster Finding 2023-001: Submission of the Audit Reporting Package and Data Collection Form (Repeat of Finding 2022-001) Criteria: The auditee is responsible for ensuring the timely submission of the audit reporting package and data collection form to the Federal Audit Clearing Housing (FAC). Condition: The audit reporting package and data collection form for the year ended September 30, 2023, was not submitted to the FAC within the timeframe as required by the Uniform Guidance. Cause: The audit was not completed as of the due date of submission. Effect: To qualify as a low-risk auditee, 2 CFR section 200.520 requires the audit reporting package and data collection form to be submitted to the FAC by the due date for each of the previous two years. Late filing will result in noncompliance with timely submission of financial information to the grantor agencies. Recommendation: We recommend the submission of the audit reporting package and the data collection form as soon as the audit is available Questioned costs: None Responsible Official's Response: We agree with the auditors' comments, and the following action will be taken to improve the situation. Semcac will be increasing capacity within the accounting department, specifically around audit tasks as well as implementing strategies throughout our programs to create efficiencies that will drive timely and accurate submission of financial transactions.
U.S. Department of Health and Human Services Pass-Through Minnesota Department of Commerce ALN 93.568 Low-Income Home Energy Assistance U.S. Department of Health and Human Services Direct ALN 93.600 Head Start Cluster Finding 2023-001: Submission of the Audit Reporting Package and Data Collection Form (Repeat of Finding 2022-001) Criteria: The auditee is responsible for ensuring the timely submission of the audit reporting package and data collection form to the Federal Audit Clearing Housing (FAC). Condition: The audit reporting package and data collection form for the year ended September 30, 2023, was not submitted to the FAC within the timeframe as required by the Uniform Guidance. Cause: The audit was not completed as of the due date of submission. Effect: To qualify as a low-risk auditee, 2 CFR section 200.520 requires the audit reporting package and data collection form to be submitted to the FAC by the due date for each of the previous two years. Late filing will result in noncompliance with timely submission of financial information to the grantor agencies. Recommendation: We recommend the submission of the audit reporting package and the data collection form as soon as the audit is available Questioned costs: None Responsible Official's Response: We agree with the auditors' comments, and the following action will be taken to improve the situation. Semcac will be increasing capacity within the accounting department, specifically around audit tasks as well as implementing strategies throughout our programs to create efficiencies that will drive timely and accurate submission of financial transactions.
U.S. Department of Health and Human Services Pass-Through Minnesota Department of Commerce ALN 93.568 Low-Income Home Energy Assistance U.S. Department of Health and Human Services Direct ALN 93.600 Head Start Cluster Finding 2023-001: Submission of the Audit Reporting Package and Data Collection Form (Repeat of Finding 2022-001) Criteria: The auditee is responsible for ensuring the timely submission of the audit reporting package and data collection form to the Federal Audit Clearing Housing (FAC). Condition: The audit reporting package and data collection form for the year ended September 30, 2023, was not submitted to the FAC within the timeframe as required by the Uniform Guidance. Cause: The audit was not completed as of the due date of submission. Effect: To qualify as a low-risk auditee, 2 CFR section 200.520 requires the audit reporting package and data collection form to be submitted to the FAC by the due date for each of the previous two years. Late filing will result in noncompliance with timely submission of financial information to the grantor agencies. Recommendation: We recommend the submission of the audit reporting package and the data collection form as soon as the audit is available Questioned costs: None Responsible Official's Response: We agree with the auditors' comments, and the following action will be taken to improve the situation. Semcac will be increasing capacity within the accounting department, specifically around audit tasks as well as implementing strategies throughout our programs to create efficiencies that will drive timely and accurate submission of financial transactions.
U.S. Department of Health and Human Services Pass-Through Minnesota Department of Commerce ALN 93.568 Low-Income Home Energy Assistance U.S. Department of Health and Human Services Direct ALN 93.600 Head Start Cluster Finding 2023-001: Submission of the Audit Reporting Package and Data Collection Form (Repeat of Finding 2022-001) Criteria: The auditee is responsible for ensuring the timely submission of the audit reporting package and data collection form to the Federal Audit Clearing Housing (FAC). Condition: The audit reporting package and data collection form for the year ended September 30, 2023, was not submitted to the FAC within the timeframe as required by the Uniform Guidance. Cause: The audit was not completed as of the due date of submission. Effect: To qualify as a low-risk auditee, 2 CFR section 200.520 requires the audit reporting package and data collection form to be submitted to the FAC by the due date for each of the previous two years. Late filing will result in noncompliance with timely submission of financial information to the grantor agencies. Recommendation: We recommend the submission of the audit reporting package and the data collection form as soon as the audit is available Questioned costs: None Responsible Official's Response: We agree with the auditors' comments, and the following action will be taken to improve the situation. Semcac will be increasing capacity within the accounting department, specifically around audit tasks as well as implementing strategies throughout our programs to create efficiencies that will drive timely and accurate submission of financial transactions.
U.S. Department of Health and Human Services Pass-Through Minnesota Department of Commerce ALN 93.568 Low-Income Home Energy Assistance U.S. Department of Health and Human Services Direct ALN 93.600 Head Start Cluster Finding 2023-001: Submission of the Audit Reporting Package and Data Collection Form (Repeat of Finding 2022-001) Criteria: The auditee is responsible for ensuring the timely submission of the audit reporting package and data collection form to the Federal Audit Clearing Housing (FAC). Condition: The audit reporting package and data collection form for the year ended September 30, 2023, was not submitted to the FAC within the timeframe as required by the Uniform Guidance. Cause: The audit was not completed as of the due date of submission. Effect: To qualify as a low-risk auditee, 2 CFR section 200.520 requires the audit reporting package and data collection form to be submitted to the FAC by the due date for each of the previous two years. Late filing will result in noncompliance with timely submission of financial information to the grantor agencies. Recommendation: We recommend the submission of the audit reporting package and the data collection form as soon as the audit is available Questioned costs: None Responsible Official's Response: We agree with the auditors' comments, and the following action will be taken to improve the situation. Semcac will be increasing capacity within the accounting department, specifically around audit tasks as well as implementing strategies throughout our programs to create efficiencies that will drive timely and accurate submission of financial transactions.
U.S. Department of Health and Human Services Pass-Through Minnesota Department of Commerce ALN 93.568 Low-Income Home Energy Assistance U.S. Department of Health and Human Services Direct ALN 93.600 Head Start Cluster Finding 2023-001: Submission of the Audit Reporting Package and Data Collection Form (Repeat of Finding 2022-001) Criteria: The auditee is responsible for ensuring the timely submission of the audit reporting package and data collection form to the Federal Audit Clearing Housing (FAC). Condition: The audit reporting package and data collection form for the year ended September 30, 2023, was not submitted to the FAC within the timeframe as required by the Uniform Guidance. Cause: The audit was not completed as of the due date of submission. Effect: To qualify as a low-risk auditee, 2 CFR section 200.520 requires the audit reporting package and data collection form to be submitted to the FAC by the due date for each of the previous two years. Late filing will result in noncompliance with timely submission of financial information to the grantor agencies. Recommendation: We recommend the submission of the audit reporting package and the data collection form as soon as the audit is available Questioned costs: None Responsible Official's Response: We agree with the auditors' comments, and the following action will be taken to improve the situation. Semcac will be increasing capacity within the accounting department, specifically around audit tasks as well as implementing strategies throughout our programs to create efficiencies that will drive timely and accurate submission of financial transactions.
U.S. Department of Health and Human Services Pass-Through Minnesota Department of Commerce ALN 93.568 Low-Income Home Energy Assistance U.S. Department of Health and Human Services Direct ALN 93.600 Head Start Cluster Finding 2023-001: Submission of the Audit Reporting Package and Data Collection Form (Repeat of Finding 2022-001) Criteria: The auditee is responsible for ensuring the timely submission of the audit reporting package and data collection form to the Federal Audit Clearing Housing (FAC). Condition: The audit reporting package and data collection form for the year ended September 30, 2023, was not submitted to the FAC within the timeframe as required by the Uniform Guidance. Cause: The audit was not completed as of the due date of submission. Effect: To qualify as a low-risk auditee, 2 CFR section 200.520 requires the audit reporting package and data collection form to be submitted to the FAC by the due date for each of the previous two years. Late filing will result in noncompliance with timely submission of financial information to the grantor agencies. Recommendation: We recommend the submission of the audit reporting package and the data collection form as soon as the audit is available Questioned costs: None Responsible Official's Response: We agree with the auditors' comments, and the following action will be taken to improve the situation. Semcac will be increasing capacity within the accounting department, specifically around audit tasks as well as implementing strategies throughout our programs to create efficiencies that will drive timely and accurate submission of financial transactions.
U.S. Department of Health and Human Services Pass-Through Minnesota Department of Commerce ALN 93.568 Low-Income Home Energy Assistance U.S. Department of Health and Human Services Direct ALN 93.600 Head Start Cluster Finding 2023-001: Submission of the Audit Reporting Package and Data Collection Form (Repeat of Finding 2022-001) Criteria: The auditee is responsible for ensuring the timely submission of the audit reporting package and data collection form to the Federal Audit Clearing Housing (FAC). Condition: The audit reporting package and data collection form for the year ended September 30, 2023, was not submitted to the FAC within the timeframe as required by the Uniform Guidance. Cause: The audit was not completed as of the due date of submission. Effect: To qualify as a low-risk auditee, 2 CFR section 200.520 requires the audit reporting package and data collection form to be submitted to the FAC by the due date for each of the previous two years. Late filing will result in noncompliance with timely submission of financial information to the grantor agencies. Recommendation: We recommend the submission of the audit reporting package and the data collection form as soon as the audit is available Questioned costs: None Responsible Official's Response: We agree with the auditors' comments, and the following action will be taken to improve the situation. Semcac will be increasing capacity within the accounting department, specifically around audit tasks as well as implementing strategies throughout our programs to create efficiencies that will drive timely and accurate submission of financial transactions.
U.S. Department of Health and Human Services Pass-Through Minnesota Department of Commerce ALN 93.568 Low-Income Home Energy Assistance U.S. Department of Health and Human Services Direct ALN 93.600 Head Start Cluster Finding 2023-001: Submission of the Audit Reporting Package and Data Collection Form (Repeat of Finding 2022-001) Criteria: The auditee is responsible for ensuring the timely submission of the audit reporting package and data collection form to the Federal Audit Clearing Housing (FAC). Condition: The audit reporting package and data collection form for the year ended September 30, 2023, was not submitted to the FAC within the timeframe as required by the Uniform Guidance. Cause: The audit was not completed as of the due date of submission. Effect: To qualify as a low-risk auditee, 2 CFR section 200.520 requires the audit reporting package and data collection form to be submitted to the FAC by the due date for each of the previous two years. Late filing will result in noncompliance with timely submission of financial information to the grantor agencies. Recommendation: We recommend the submission of the audit reporting package and the data collection form as soon as the audit is available Questioned costs: None Responsible Official's Response: We agree with the auditors' comments, and the following action will be taken to improve the situation. Semcac will be increasing capacity within the accounting department, specifically around audit tasks as well as implementing strategies throughout our programs to create efficiencies that will drive timely and accurate submission of financial transactions.
U.S. Department of Health and Human Services Pass-Through Minnesota Department of Commerce ALN 93.568 Low-Income Home Energy Assistance U.S. Department of Health and Human Services Direct ALN 93.600 Head Start Cluster Finding 2023-001: Submission of the Audit Reporting Package and Data Collection Form (Repeat of Finding 2022-001) Criteria: The auditee is responsible for ensuring the timely submission of the audit reporting package and data collection form to the Federal Audit Clearing Housing (FAC). Condition: The audit reporting package and data collection form for the year ended September 30, 2023, was not submitted to the FAC within the timeframe as required by the Uniform Guidance. Cause: The audit was not completed as of the due date of submission. Effect: To qualify as a low-risk auditee, 2 CFR section 200.520 requires the audit reporting package and data collection form to be submitted to the FAC by the due date for each of the previous two years. Late filing will result in noncompliance with timely submission of financial information to the grantor agencies. Recommendation: We recommend the submission of the audit reporting package and the data collection form as soon as the audit is available Questioned costs: None Responsible Official's Response: We agree with the auditors' comments, and the following action will be taken to improve the situation. Semcac will be increasing capacity within the accounting department, specifically around audit tasks as well as implementing strategies throughout our programs to create efficiencies that will drive timely and accurate submission of financial transactions.
U.S. Department of Health and Human Services Pass-Through Minnesota Department of Commerce ALN 93.568 Low-Income Home Energy Assistance U.S. Department of Health and Human Services Direct ALN 93.600 Head Start Cluster Finding 2023-001: Submission of the Audit Reporting Package and Data Collection Form (Repeat of Finding 2022-001) Criteria: The auditee is responsible for ensuring the timely submission of the audit reporting package and data collection form to the Federal Audit Clearing Housing (FAC). Condition: The audit reporting package and data collection form for the year ended September 30, 2023, was not submitted to the FAC within the timeframe as required by the Uniform Guidance. Cause: The audit was not completed as of the due date of submission. Effect: To qualify as a low-risk auditee, 2 CFR section 200.520 requires the audit reporting package and data collection form to be submitted to the FAC by the due date for each of the previous two years. Late filing will result in noncompliance with timely submission of financial information to the grantor agencies. Recommendation: We recommend the submission of the audit reporting package and the data collection form as soon as the audit is available Questioned costs: None Responsible Official's Response: We agree with the auditors' comments, and the following action will be taken to improve the situation. Semcac will be increasing capacity within the accounting department, specifically around audit tasks as well as implementing strategies throughout our programs to create efficiencies that will drive timely and accurate submission of financial transactions.
U.S. Department of Health and Human Services Pass-Through Minnesota Department of Commerce ALN 93.568 Low-Income Home Energy Assistance U.S. Department of Health and Human Services Direct ALN 93.600 Head Start Cluster Finding 2023-001: Submission of the Audit Reporting Package and Data Collection Form (Repeat of Finding 2022-001) Criteria: The auditee is responsible for ensuring the timely submission of the audit reporting package and data collection form to the Federal Audit Clearing Housing (FAC). Condition: The audit reporting package and data collection form for the year ended September 30, 2023, was not submitted to the FAC within the timeframe as required by the Uniform Guidance. Cause: The audit was not completed as of the due date of submission. Effect: To qualify as a low-risk auditee, 2 CFR section 200.520 requires the audit reporting package and data collection form to be submitted to the FAC by the due date for each of the previous two years. Late filing will result in noncompliance with timely submission of financial information to the grantor agencies. Recommendation: We recommend the submission of the audit reporting package and the data collection form as soon as the audit is available Questioned costs: None Responsible Official's Response: We agree with the auditors' comments, and the following action will be taken to improve the situation. Semcac will be increasing capacity within the accounting department, specifically around audit tasks as well as implementing strategies throughout our programs to create efficiencies that will drive timely and accurate submission of financial transactions.
2023-004: Procurement Federal Agency: Department of Education, United States Department of Agriculture, Federal Aviation Administration Federal Program Title: GEAR UP Mississippi, Improving Efficiency in Catfish Aquaculture, ASSURE Assistance Listing Number: 84.334, 10.001, 20.109 Award Number and Year: P334S190003 (August 23, 2019 – August 22, 2026), 58-6066-0-031 (April 1, 2020 – March 31, 2025), 15-C-UAS-MSU-A (May 8, 2015 – May 7, 2025) Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Applicable Institution: Mississippi State University (MSU) Criteria or Specific Requirement: Internal Control – Per 2 CFR section 200.303(a), a non-Federal 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. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Compliance – Per 2 CFR 200.320: Non-Federal entities may establish a threshold higher than the micro-purchase threshold identified in the FAR in accordance with the requirements of this section. The non-Federal entity may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the Federal awarding agency and auditors in accordance with § 200.334. The self-certification must include a justification, clear identification of the threshold, and supporting documentation of any of the following: (A) A qualification as a low-risk auditee, in accordance with the criteria in § 200.520 for the most recent audit; (B) An annual internal institutional risk assessment to identify, mitigate, and manage financial risks; or, (C) For public institutions, a higher threshold consistent with State law. Micro-purchase thresholds higher than $50,000 must be approved by the cognizant agency for indirect costs. The non-federal entity must submit a request with the requirements included in paragraph (a)(1)(iv) of this section. The increased threshold is valid until there is a change in status in which the justification was approved. Condition: MSU established a micro-purchase threshold of $75,000 for contracted services and was not able to provide documentation to support this threshold. Questioned Costs: None. Context: For 3 out of the 7 contracts tested, the dollar amount of the contract was above the Federally established Micro-Threshold of $10,000, and price or rate quotations were not obtained providing for full and open competition. Cause: Mississippi State University’s Procurement and Contracts Manual was updated in August 2022; however, the section addressing federal requirements was not properly addressed. Effect: The institution procured services with a policy not meeting Federal requirements. Repeat Finding: No Recommendation: We recommend the institution review and revise their current procurement policy and review requirements to ensure that their policy is meeting Federal requirements. Views of Responsible Officials: There is no disagreement with the audit finding.
2023-004: Procurement Federal Agency: Department of Education, United States Department of Agriculture, Federal Aviation Administration Federal Program Title: GEAR UP Mississippi, Improving Efficiency in Catfish Aquaculture, ASSURE Assistance Listing Number: 84.334, 10.001, 20.109 Award Number and Year: P334S190003 (August 23, 2019 – August 22, 2026), 58-6066-0-031 (April 1, 2020 – March 31, 2025), 15-C-UAS-MSU-A (May 8, 2015 – May 7, 2025) Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Applicable Institution: Mississippi State University (MSU) Criteria or Specific Requirement: Internal Control – Per 2 CFR section 200.303(a), a non-Federal 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. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Compliance – Per 2 CFR 200.320: Non-Federal entities may establish a threshold higher than the micro-purchase threshold identified in the FAR in accordance with the requirements of this section. The non-Federal entity may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the Federal awarding agency and auditors in accordance with § 200.334. The self-certification must include a justification, clear identification of the threshold, and supporting documentation of any of the following: (A) A qualification as a low-risk auditee, in accordance with the criteria in § 200.520 for the most recent audit; (B) An annual internal institutional risk assessment to identify, mitigate, and manage financial risks; or, (C) For public institutions, a higher threshold consistent with State law. Micro-purchase thresholds higher than $50,000 must be approved by the cognizant agency for indirect costs. The non-federal entity must submit a request with the requirements included in paragraph (a)(1)(iv) of this section. The increased threshold is valid until there is a change in status in which the justification was approved. Condition: MSU established a micro-purchase threshold of $75,000 for contracted services and was not able to provide documentation to support this threshold. Questioned Costs: None. Context: For 3 out of the 7 contracts tested, the dollar amount of the contract was above the Federally established Micro-Threshold of $10,000, and price or rate quotations were not obtained providing for full and open competition. Cause: Mississippi State University’s Procurement and Contracts Manual was updated in August 2022; however, the section addressing federal requirements was not properly addressed. Effect: The institution procured services with a policy not meeting Federal requirements. Repeat Finding: No Recommendation: We recommend the institution review and revise their current procurement policy and review requirements to ensure that their policy is meeting Federal requirements. Views of Responsible Officials: There is no disagreement with the audit finding.
2023-004: Procurement Federal Agency: Department of Education, United States Department of Agriculture, Federal Aviation Administration Federal Program Title: GEAR UP Mississippi, Improving Efficiency in Catfish Aquaculture, ASSURE Assistance Listing Number: 84.334, 10.001, 20.109 Award Number and Year: P334S190003 (August 23, 2019 – August 22, 2026), 58-6066-0-031 (April 1, 2020 – March 31, 2025), 15-C-UAS-MSU-A (May 8, 2015 – May 7, 2025) Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Applicable Institution: Mississippi State University (MSU) Criteria or Specific Requirement: Internal Control – Per 2 CFR section 200.303(a), a non-Federal 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. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Compliance – Per 2 CFR 200.320: Non-Federal entities may establish a threshold higher than the micro-purchase threshold identified in the FAR in accordance with the requirements of this section. The non-Federal entity may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the Federal awarding agency and auditors in accordance with § 200.334. The self-certification must include a justification, clear identification of the threshold, and supporting documentation of any of the following: (A) A qualification as a low-risk auditee, in accordance with the criteria in § 200.520 for the most recent audit; (B) An annual internal institutional risk assessment to identify, mitigate, and manage financial risks; or, (C) For public institutions, a higher threshold consistent with State law. Micro-purchase thresholds higher than $50,000 must be approved by the cognizant agency for indirect costs. The non-federal entity must submit a request with the requirements included in paragraph (a)(1)(iv) of this section. The increased threshold is valid until there is a change in status in which the justification was approved. Condition: MSU established a micro-purchase threshold of $75,000 for contracted services and was not able to provide documentation to support this threshold. Questioned Costs: None. Context: For 3 out of the 7 contracts tested, the dollar amount of the contract was above the Federally established Micro-Threshold of $10,000, and price or rate quotations were not obtained providing for full and open competition. Cause: Mississippi State University’s Procurement and Contracts Manual was updated in August 2022; however, the section addressing federal requirements was not properly addressed. Effect: The institution procured services with a policy not meeting Federal requirements. Repeat Finding: No Recommendation: We recommend the institution review and revise their current procurement policy and review requirements to ensure that their policy is meeting Federal requirements. Views of Responsible Officials: There is no disagreement with the audit finding.
Programs: Child Nutrition Cluster, Impact Aid, Education Stabilization Fund (COVID-19) Federal Assistance #: 10.553, 10.555, 10.559, 84.041, 84.425 Federal Agency: U.S. Department of Agriculture and U.S. Department of Education Grantor Number: N/A Questioned Costs: N/A Type of Finding: Noncompliance Compliance Requirement: L. Reporting Condition: The District did not submit their audit for the fiscal year ending June 30, 2023, timely. The audit was submitted May 16, 2024, which was 46 days past the March 31, 2024 deadline. Criteria: 2 CFR § 200.512(a) provides, in part: "The audit must be completed and the data collection form ... must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period." 2 CFR § 200.520 provides, in part: "That to qualify as a low-risk auditee and be eligible for reduced audit coverage the following condition must be met: Single audits were performed on an annual basis in accordance with the provisions of this Subpart, including submitting the data collection form and the reporting package to the FAC within the timeframe specified in § 200.512." Cause: The District was the victim of a ransomware attack in August 2022 which led to a delay in the audit process as records were being retrieved and reposted. Effect: Not making all audit documentation available in a timely manner resulted in the audit and data collection form submissions to be late and, therefore, not available to the public within the required timeframe. This late submission also excludes the District from qualifying as a low-risk auditee. Recommendation: The District should implement procedures to ensure that all audit documentation is available for auditing in a timely manner and the audit report is completed and submitted within the appropriate timeframe. Repeat Finding: Same as prior year finding 2022-006. Contact person: Becky Tinney, Business Manager
Programs: Indian School Equalization Program, Administrative Cost Grants for Indian Schools, Indian Education Facilities, Operations, and Maintenance, and Special Education Cluster Federal Assistance #: 15.042, 15.046, 15.047, and 84.027 Federal Agency: U.S. Department of the Interior and U.S. Department of Education Grantor Number: N/A Questioned Costs: N/A Type of Finding: Noncompliance Compliance Requirement: L. Reporting Condition: The School did not submit their audit for the fiscal year ending June 30, 2023, timely. The audit was submitted May 28, 2024, which was 58 days past the March 31, 2024 deadline. Criteria: 2 CFR § 200.512(a) provides, in part: "The audit must be completed and the data collection form ... must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period." 2 CFR § 200.520 provides, in part: "That to qualify as a low-risk auditee and be eligible for reduced audit coverage the following condition must be met: Single audits were performed on an annual basis in accordance with the provisions of this Subpart, including submitting the data collection form and the reporting package to the FAC within the timeframe specified in § 200.512." Cause: Management turnover Effect: Not making all audit documentation available in a timely manner resulted in the audit and data collection form submissions to be late and, therefore, not available to the public within the required timeframe. This late submission also excludes the School from qualifying as a low-risk auditee. Recommendation: The School should implement procedures to ensure that all audit documentation is available for auditing in a timely manner and the audit report is completed and submitted within the appropriate timeframe. Repeat Finding: Same as prior year finding 2022-03. Contact person: Jagdish Sharma, Principal
Finding Number: 2023-005 Repeat Finding: Similar to prior year finding 2022-004 Program Name/Assistance Listing Title: Indian School Equalization Program, Administrative Cost Grants for Indian Schools, Indian Education Facilities, Operations, and Maintenance, Special Education Cluster, and Education Stabilization Fund - COVID-19 Assistance Listing Number: 15.042, 15.046, 15.047, 21.027, 84.010, 84.027, and 84.425D Federal Agency: U.S. Department of the Interior, U.S. Department of Treasury, U.S. Department of Education Federal Award Number: A22AV00792, Unknown (21.027) Questioned Costs: None Type of Finding: Noncompliance, Material Weakness Compliance Requirement: Reporting Criteria: 2 CFR § 200.512(a) provides, in part: "The audit must be completed and the data collection form ... must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period." 2 CFR § 200.520 provides, in part: "That to qualify as a low-risk auditee and be eligible for reduced audit coverage the following condition must be met: Single audits were performed on an annual basis in accordance with the provisions of this Subpart, including submitting the data collection form and the reporting package to the FAC within the timeframe specified in § 200.512." Condition: The School did submit their audit for the fiscal year ending June 30, 2023 timely. The audit was submitted August 16, 2024, which was 138 days past the March 31, 2024 deadline. Effect: Not making all audit documentation available in a timely manner resulted in the audit and data collection form submissions to be late and, therefore, not available to the public within the required timeframe. This late submission also excludes the School from qualifying as a low-risk auditee. Cause: Management oversight. Recommendation: The School should implement procedures to ensure that all audit documentation is available for the audit in a timely manner and the audit report is completed and submitted within the appropriate timeframe. Response: The School’s responses are presented in a separate document. Contact person: Dolores Silva, Chief Financial Officer
Finding Number: 2023-005 Repeat Finding: Similar to prior year finding 2022-004 Program Name/Assistance Listing Title: Indian School Equalization Program, Administrative Cost Grants for Indian Schools, Indian Education Facilities, Operations, and Maintenance, Special Education Cluster, and Education Stabilization Fund - COVID-19 Assistance Listing Number: 15.042, 15.046, 15.047, 21.027, 84.010, 84.027, and 84.425D Federal Agency: U.S. Department of the Interior, U.S. Department of Treasury, U.S. Department of Education Federal Award Number: A22AV00792, Unknown (21.027) Questioned Costs: None Type of Finding: Noncompliance, Material Weakness Compliance Requirement: Reporting Criteria: 2 CFR § 200.512(a) provides, in part: "The audit must be completed and the data collection form ... must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period." 2 CFR § 200.520 provides, in part: "That to qualify as a low-risk auditee and be eligible for reduced audit coverage the following condition must be met: Single audits were performed on an annual basis in accordance with the provisions of this Subpart, including submitting the data collection form and the reporting package to the FAC within the timeframe specified in § 200.512." Condition: The School did submit their audit for the fiscal year ending June 30, 2023 timely. The audit was submitted August 16, 2024, which was 138 days past the March 31, 2024 deadline. Effect: Not making all audit documentation available in a timely manner resulted in the audit and data collection form submissions to be late and, therefore, not available to the public within the required timeframe. This late submission also excludes the School from qualifying as a low-risk auditee. Cause: Management oversight. Recommendation: The School should implement procedures to ensure that all audit documentation is available for the audit in a timely manner and the audit report is completed and submitted within the appropriate timeframe. Response: The School’s responses are presented in a separate document. Contact person: Dolores Silva, Chief Financial Officer
Finding Number: 2023-005 Repeat Finding: Similar to prior year finding 2022-004 Program Name/Assistance Listing Title: Indian School Equalization Program, Administrative Cost Grants for Indian Schools, Indian Education Facilities, Operations, and Maintenance, Special Education Cluster, and Education Stabilization Fund - COVID-19 Assistance Listing Number: 15.042, 15.046, 15.047, 21.027, 84.010, 84.027, and 84.425D Federal Agency: U.S. Department of the Interior, U.S. Department of Treasury, U.S. Department of Education Federal Award Number: A22AV00792, Unknown (21.027) Questioned Costs: None Type of Finding: Noncompliance, Material Weakness Compliance Requirement: Reporting Criteria: 2 CFR § 200.512(a) provides, in part: "The audit must be completed and the data collection form ... must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period." 2 CFR § 200.520 provides, in part: "That to qualify as a low-risk auditee and be eligible for reduced audit coverage the following condition must be met: Single audits were performed on an annual basis in accordance with the provisions of this Subpart, including submitting the data collection form and the reporting package to the FAC within the timeframe specified in § 200.512." Condition: The School did submit their audit for the fiscal year ending June 30, 2023 timely. The audit was submitted August 16, 2024, which was 138 days past the March 31, 2024 deadline. Effect: Not making all audit documentation available in a timely manner resulted in the audit and data collection form submissions to be late and, therefore, not available to the public within the required timeframe. This late submission also excludes the School from qualifying as a low-risk auditee. Cause: Management oversight. Recommendation: The School should implement procedures to ensure that all audit documentation is available for the audit in a timely manner and the audit report is completed and submitted within the appropriate timeframe. Response: The School’s responses are presented in a separate document. Contact person: Dolores Silva, Chief Financial Officer
Finding Number: 2023-005 Repeat Finding: Similar to prior year finding 2022-004 Program Name/Assistance Listing Title: Indian School Equalization Program, Administrative Cost Grants for Indian Schools, Indian Education Facilities, Operations, and Maintenance, Special Education Cluster, and Education Stabilization Fund - COVID-19 Assistance Listing Number: 15.042, 15.046, 15.047, 21.027, 84.010, 84.027, and 84.425D Federal Agency: U.S. Department of the Interior, U.S. Department of Treasury, U.S. Department of Education Federal Award Number: A22AV00792, Unknown (21.027) Questioned Costs: None Type of Finding: Noncompliance, Material Weakness Compliance Requirement: Reporting Criteria: 2 CFR § 200.512(a) provides, in part: "The audit must be completed and the data collection form ... must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period." 2 CFR § 200.520 provides, in part: "That to qualify as a low-risk auditee and be eligible for reduced audit coverage the following condition must be met: Single audits were performed on an annual basis in accordance with the provisions of this Subpart, including submitting the data collection form and the reporting package to the FAC within the timeframe specified in § 200.512." Condition: The School did submit their audit for the fiscal year ending June 30, 2023 timely. The audit was submitted August 16, 2024, which was 138 days past the March 31, 2024 deadline. Effect: Not making all audit documentation available in a timely manner resulted in the audit and data collection form submissions to be late and, therefore, not available to the public within the required timeframe. This late submission also excludes the School from qualifying as a low-risk auditee. Cause: Management oversight. Recommendation: The School should implement procedures to ensure that all audit documentation is available for the audit in a timely manner and the audit report is completed and submitted within the appropriate timeframe. Response: The School’s responses are presented in a separate document. Contact person: Dolores Silva, Chief Financial Officer
Finding Number: 2023-005 Repeat Finding: Similar to prior year finding 2022-004 Program Name/Assistance Listing Title: Indian School Equalization Program, Administrative Cost Grants for Indian Schools, Indian Education Facilities, Operations, and Maintenance, Special Education Cluster, and Education Stabilization Fund - COVID-19 Assistance Listing Number: 15.042, 15.046, 15.047, 21.027, 84.010, 84.027, and 84.425D Federal Agency: U.S. Department of the Interior, U.S. Department of Treasury, U.S. Department of Education Federal Award Number: A22AV00792, Unknown (21.027) Questioned Costs: None Type of Finding: Noncompliance, Material Weakness Compliance Requirement: Reporting Criteria: 2 CFR § 200.512(a) provides, in part: "The audit must be completed and the data collection form ... must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period." 2 CFR § 200.520 provides, in part: "That to qualify as a low-risk auditee and be eligible for reduced audit coverage the following condition must be met: Single audits were performed on an annual basis in accordance with the provisions of this Subpart, including submitting the data collection form and the reporting package to the FAC within the timeframe specified in § 200.512." Condition: The School did submit their audit for the fiscal year ending June 30, 2023 timely. The audit was submitted August 16, 2024, which was 138 days past the March 31, 2024 deadline. Effect: Not making all audit documentation available in a timely manner resulted in the audit and data collection form submissions to be late and, therefore, not available to the public within the required timeframe. This late submission also excludes the School from qualifying as a low-risk auditee. Cause: Management oversight. Recommendation: The School should implement procedures to ensure that all audit documentation is available for the audit in a timely manner and the audit report is completed and submitted within the appropriate timeframe. Response: The School’s responses are presented in a separate document. Contact person: Dolores Silva, Chief Financial Officer
Finding Number: 2023-005 Repeat Finding: Similar to prior year finding 2022-004 Program Name/Assistance Listing Title: Indian School Equalization Program, Administrative Cost Grants for Indian Schools, Indian Education Facilities, Operations, and Maintenance, Special Education Cluster, and Education Stabilization Fund - COVID-19 Assistance Listing Number: 15.042, 15.046, 15.047, 21.027, 84.010, 84.027, and 84.425D Federal Agency: U.S. Department of the Interior, U.S. Department of Treasury, U.S. Department of Education Federal Award Number: A22AV00792, Unknown (21.027) Questioned Costs: None Type of Finding: Noncompliance, Material Weakness Compliance Requirement: Reporting Criteria: 2 CFR § 200.512(a) provides, in part: "The audit must be completed and the data collection form ... must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period." 2 CFR § 200.520 provides, in part: "That to qualify as a low-risk auditee and be eligible for reduced audit coverage the following condition must be met: Single audits were performed on an annual basis in accordance with the provisions of this Subpart, including submitting the data collection form and the reporting package to the FAC within the timeframe specified in § 200.512." Condition: The School did submit their audit for the fiscal year ending June 30, 2023 timely. The audit was submitted August 16, 2024, which was 138 days past the March 31, 2024 deadline. Effect: Not making all audit documentation available in a timely manner resulted in the audit and data collection form submissions to be late and, therefore, not available to the public within the required timeframe. This late submission also excludes the School from qualifying as a low-risk auditee. Cause: Management oversight. Recommendation: The School should implement procedures to ensure that all audit documentation is available for the audit in a timely manner and the audit report is completed and submitted within the appropriate timeframe. Response: The School’s responses are presented in a separate document. Contact person: Dolores Silva, Chief Financial Officer
Finding Number: 2023-005 Repeat Finding: Similar to prior year finding 2022-004 Program Name/Assistance Listing Title: Indian School Equalization Program, Administrative Cost Grants for Indian Schools, Indian Education Facilities, Operations, and Maintenance, Special Education Cluster, and Education Stabilization Fund - COVID-19 Assistance Listing Number: 15.042, 15.046, 15.047, 21.027, 84.010, 84.027, and 84.425D Federal Agency: U.S. Department of the Interior, U.S. Department of Treasury, U.S. Department of Education Federal Award Number: A22AV00792, Unknown (21.027) Questioned Costs: None Type of Finding: Noncompliance, Material Weakness Compliance Requirement: Reporting Criteria: 2 CFR § 200.512(a) provides, in part: "The audit must be completed and the data collection form ... must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period." 2 CFR § 200.520 provides, in part: "That to qualify as a low-risk auditee and be eligible for reduced audit coverage the following condition must be met: Single audits were performed on an annual basis in accordance with the provisions of this Subpart, including submitting the data collection form and the reporting package to the FAC within the timeframe specified in § 200.512." Condition: The School did submit their audit for the fiscal year ending June 30, 2023 timely. The audit was submitted August 16, 2024, which was 138 days past the March 31, 2024 deadline. Effect: Not making all audit documentation available in a timely manner resulted in the audit and data collection form submissions to be late and, therefore, not available to the public within the required timeframe. This late submission also excludes the School from qualifying as a low-risk auditee. Cause: Management oversight. Recommendation: The School should implement procedures to ensure that all audit documentation is available for the audit in a timely manner and the audit report is completed and submitted within the appropriate timeframe. Response: The School’s responses are presented in a separate document. Contact person: Dolores Silva, Chief Financial Officer
Finding Number: 2023-004 Repeat Finding: No. Program Name/Assistance Listing Title: Indian School Equalization Program Assistance Listing Number: 15.042 Federal Agency: U.S. Department of the Interior Federal Award Number: A22AV00848 Questioned Costs: None Type of Finding: Noncompliance, Material Weakness Compliance Requirement: Reporting Criteria: 2 CFR § 200.512(a) provides, in part: "The audit must be completed and the data collection form ... must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period." 2 CFR § 200.520 provides, in part: "That to qualify as a low-risk auditee and be eligible for reduced audit coverage the following condition must be met: Single audits were performed on an annual basis in accordance with the provisions of this Subpart, including submitting the data collection form and the reporting package to the FAC within the timeframe specified in § 200.512." Condition: The School did submit their audit for the fiscal year ending June 30, 2023 timely. The audit was submitted December 6, 2024, which was 250 days past the March 31, 2024 deadline. Effect: Not making all audit documentation available in a timely manner resulted in the audit and data collection form submissions to be late and, therefore, not available to the public within the required timeframe. This late submission also excludes the School from qualifying as a low-risk auditee. Cause: Management oversight. Recommendation: The School should implement procedures to ensure that all audit documentation is available for the audit in a timely manner and the audit report is completed and submitted within the appropriate timeframe. Response: The School concurs with this recommendation and will implement procedures to ensure compliance with federal regulation. Contact person: Marie Rose, Principal
2023-004: Procurement Federal Agency: Department of Education, United States Department of Agriculture, Federal Aviation Administration Federal Program Title: GEAR UP Mississippi, Improving Efficiency in Catfish Aquaculture, ASSURE Assistance Listing Number: 84.334, 10.001, 20.109 Award Number and Year: P334S190003 (August 23, 2019 – August 22, 2026), 58-6066-0-031 (April 1, 2020 – March 31, 2025), 15-C-UAS-MSU-A (May 8, 2015 – May 7, 2025) Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Applicable Institution: Mississippi State University (MSU) Criteria or Specific Requirement: Internal Control – Per 2 CFR section 200.303(a), a non-Federal 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. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Compliance – Per 2 CFR 200.320: Non-Federal entities may establish a threshold higher than the micro-purchase threshold identified in the FAR in accordance with the requirements of this section. The non-Federal entity may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the Federal awarding agency and auditors in accordance with § 200.334. The self-certification must include a justification, clear identification of the threshold, and supporting documentation of any of the following: (A) A qualification as a low-risk auditee, in accordance with the criteria in § 200.520 for the most recent audit; (B) An annual internal institutional risk assessment to identify, mitigate, and manage financial risks; or, (C) For public institutions, a higher threshold consistent with State law. Micro-purchase thresholds higher than $50,000 must be approved by the cognizant agency for indirect costs. The non-federal entity must submit a request with the requirements included in paragraph (a)(1)(iv) of this section. The increased threshold is valid until there is a change in status in which the justification was approved. Condition: MSU established a micro-purchase threshold of $75,000 for contracted services and was not able to provide documentation to support this threshold. Questioned Costs: None. Context: For 3 out of the 7 contracts tested, the dollar amount of the contract was above the Federally established Micro-Threshold of $10,000, and price or rate quotations were not obtained providing for full and open competition. Cause: Mississippi State University’s Procurement and Contracts Manual was updated in August 2022; however, the section addressing federal requirements was not properly addressed. Effect: The institution procured services with a policy not meeting Federal requirements. Repeat Finding: No Recommendation: We recommend the institution review and revise their current procurement policy and review requirements to ensure that their policy is meeting Federal requirements. Views of Responsible Officials: There is no disagreement with the audit finding.
2023-004: Procurement Federal Agency: Department of Education, United States Department of Agriculture, Federal Aviation Administration Federal Program Title: GEAR UP Mississippi, Improving Efficiency in Catfish Aquaculture, ASSURE Assistance Listing Number: 84.334, 10.001, 20.109 Award Number and Year: P334S190003 (August 23, 2019 – August 22, 2026), 58-6066-0-031 (April 1, 2020 – March 31, 2025), 15-C-UAS-MSU-A (May 8, 2015 – May 7, 2025) Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Applicable Institution: Mississippi State University (MSU) Criteria or Specific Requirement: Internal Control – Per 2 CFR section 200.303(a), a non-Federal 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. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Compliance – Per 2 CFR 200.320: Non-Federal entities may establish a threshold higher than the micro-purchase threshold identified in the FAR in accordance with the requirements of this section. The non-Federal entity may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the Federal awarding agency and auditors in accordance with § 200.334. The self-certification must include a justification, clear identification of the threshold, and supporting documentation of any of the following: (A) A qualification as a low-risk auditee, in accordance with the criteria in § 200.520 for the most recent audit; (B) An annual internal institutional risk assessment to identify, mitigate, and manage financial risks; or, (C) For public institutions, a higher threshold consistent with State law. Micro-purchase thresholds higher than $50,000 must be approved by the cognizant agency for indirect costs. The non-federal entity must submit a request with the requirements included in paragraph (a)(1)(iv) of this section. The increased threshold is valid until there is a change in status in which the justification was approved. Condition: MSU established a micro-purchase threshold of $75,000 for contracted services and was not able to provide documentation to support this threshold. Questioned Costs: None. Context: For 3 out of the 7 contracts tested, the dollar amount of the contract was above the Federally established Micro-Threshold of $10,000, and price or rate quotations were not obtained providing for full and open competition. Cause: Mississippi State University’s Procurement and Contracts Manual was updated in August 2022; however, the section addressing federal requirements was not properly addressed. Effect: The institution procured services with a policy not meeting Federal requirements. Repeat Finding: No Recommendation: We recommend the institution review and revise their current procurement policy and review requirements to ensure that their policy is meeting Federal requirements. Views of Responsible Officials: There is no disagreement with the audit finding.