Assistance Listings number and name: 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds (SLFRF) Award number and year: None Federal agency: U.S. Department of the Treasury Questioned costs: $1,903,858 Assistance Listing number and name: 84.425C COVID-19 Education Stabilization Fund – Governor’s Emergency Education Relief (GEER) Fund Award numbers and years: S425C200052, June 2, 2020 through September 30, 2022; S425C210052, January 8, 2021 through September 30, 2023 Federal agency: U.S. Department of Education Questioned costs: Unknown Compliance requirement: Subrecipient monitoring Condition—The Governor’s Office of Strategic Planning and Budgeting (Office) awarded $135.1 million to 334 SLFRF program subrecipients and $10.2 million to 10 GEER program subrecipients during fiscal year 2023, or 88 percent and 98 percent, respectively, of each of the Office’s federal program expenditures, but did not perform all required risk assessments to assess whether its monitoring procedures were sufficient to evaluate whether subrecipients used program monies in accordance with the award terms and program requirements. Specifically, risk assessments were not performed for 37 of 42 SLFRF program subrecipients and 5 of 5 GEER program subrecipients tested. Effect—The Office’s delay in performing required risk assessments did not allow the Office to properly design and prioritize its monitoring efforts, resulting in the Office not timely identifying questioned costs of approximately $1,903,858 for 3 SLFRF program subrecipients that may not have been spent in accordance with program requirements.1 The Office identified several of these questioned costs as potentially inappropriate and has forwarded this information to the Attorney General’s Office for further review. As a result, the Office may be required to return these monies to the federal agency in accordance with Uniform Guidance requirements.2 Further, if monies were spent inconsistent with program requirements, those who were intended to benefit from the program may not have received all the services or other benefits they otherwise would have received. Subrecipient program expenditures are not related to the revenue loss expenditure category. Cause—Office management reported that it hired additional staff in fiscal year 2023 to begin addressing issues noted in prior year findings 2022-104 and 2022-10 but had not done so in time to complete required risk assessments for the more than 300 SLFRF program and 10 GEER program subrecipients.3 Criteria—Federal regulation requires the Office to monitor subrecipients, which includes required monitoring procedures for assessing the risk of each subrecipient’s noncompliance and monitoring activities based on those risk assessments. This federal regulation also provides that monitoring procedures may include reviewing financial and performance reports, providing training or technical assistance on program-related matters, and performing on-site reviews, selective audits, and/or other monitoring procedures (2 CFR §200.332[b] and [e]). Further, Office policy requires an annual risk assessment of open, active subawards to determine which subawards will be selected for review and monitoring priority (Grants Management Manual – Grantor, Chapter 8 – Award Monitoring). Finally, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that the federal program is being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations—The Office should: 1. Ensure it performs required monitoring of its subrecipients and their compliance with the award terms and program requirements by following its established policies and procedures to assess the risk of each subrecipient’s noncompliance annually and carry out monitoring activities based on those risk assessments such as reviewing financial and performance reports, providing training or technical assistance on program-related matters, and performing on site reviews, selective audits, and/or other monitoring procedures. 2. Continue to assess its resources, such as staffing, to perform required risk assessments and monitoring procedures to comply with the award terms and program requirements. 3. Work with the federal agency and the subrecipients to resolve the $1,903,858 of program monies that may have been spent in violation of its federal award terms and that may need to be returned to the federal agency.2 The State’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year findings 2022-104 (GEER) and 2022-106 (SLFRF) and were initially reported in fiscal years 2021 (GEER) and 2022 (SLFRF). 1 The Office reported during fiscal year 2024 it began performing missing risk assessments for subrecipients awarded monies during fiscal years 2022 and 2023 that were not completed by June 30, 2023, and is currently conducting additional onsite monitoring or desk reviews based on those results. As of the report date, December 17, 2024, the Office identified and reported to us approximately $1,903,858 of expenditures for 3 SLFRF program subrecipients that may not have been spent in accordance with program requirements. Since the Office is still performing monitoring procedures for subaward monies spent during fiscal year 2023, there may be additional questioned costs that the Office has not identified. 2 Federal Uniform Guidance requires federal awarding agencies to follow up on audit findings and issue a management decision to ensure the recipient, the Office, takes appropriate and timely corrective action (2 CFR §200.513[c]). Further, it requires that federal awarding agencies’ management decisions clearly state whether or not the audit finding is sustained, the reasons for the decision, and the expected auditee action to repay disallowed costs, make financial adjustments, or take other action, as directed by the federal awarding agencies (2 CFR §200.521). 3 Arizona Auditor General. (2023). State of Arizona June 30, 2022, Single Audit Report. Phoenix, AZ. Retrieved 08/13/2024 from https://www.azauditor.gov/sites/default/files/2024-01/StateOfArizonaJune30_2022SingleAudit.pdf
Assistance Listings number and name: 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds (SLFRF) Award number and year: None Federal agency: U.S. Department of the Treasury Questioned costs: $1,903,858 Assistance Listing number and name: 84.425C COVID-19 Education Stabilization Fund – Governor’s Emergency Education Relief (GEER) Fund Award numbers and years: S425C200052, June 2, 2020 through September 30, 2022; S425C210052, January 8, 2021 through September 30, 2023 Federal agency: U.S. Department of Education Questioned costs: Unknown Compliance requirement: Subrecipient monitoring Condition—The Governor’s Office of Strategic Planning and Budgeting (Office) awarded $135.1 million to 334 SLFRF program subrecipients and $10.2 million to 10 GEER program subrecipients during fiscal year 2023, or 88 percent and 98 percent, respectively, of each of the Office’s federal program expenditures, but did not perform all required risk assessments to assess whether its monitoring procedures were sufficient to evaluate whether subrecipients used program monies in accordance with the award terms and program requirements. Specifically, risk assessments were not performed for 37 of 42 SLFRF program subrecipients and 5 of 5 GEER program subrecipients tested. Effect—The Office’s delay in performing required risk assessments did not allow the Office to properly design and prioritize its monitoring efforts, resulting in the Office not timely identifying questioned costs of approximately $1,903,858 for 3 SLFRF program subrecipients that may not have been spent in accordance with program requirements.1 The Office identified several of these questioned costs as potentially inappropriate and has forwarded this information to the Attorney General’s Office for further review. As a result, the Office may be required to return these monies to the federal agency in accordance with Uniform Guidance requirements.2 Further, if monies were spent inconsistent with program requirements, those who were intended to benefit from the program may not have received all the services or other benefits they otherwise would have received. Subrecipient program expenditures are not related to the revenue loss expenditure category. Cause—Office management reported that it hired additional staff in fiscal year 2023 to begin addressing issues noted in prior year findings 2022-104 and 2022-10 but had not done so in time to complete required risk assessments for the more than 300 SLFRF program and 10 GEER program subrecipients.3 Criteria—Federal regulation requires the Office to monitor subrecipients, which includes required monitoring procedures for assessing the risk of each subrecipient’s noncompliance and monitoring activities based on those risk assessments. This federal regulation also provides that monitoring procedures may include reviewing financial and performance reports, providing training or technical assistance on program-related matters, and performing on-site reviews, selective audits, and/or other monitoring procedures (2 CFR §200.332[b] and [e]). Further, Office policy requires an annual risk assessment of open, active subawards to determine which subawards will be selected for review and monitoring priority (Grants Management Manual – Grantor, Chapter 8 – Award Monitoring). Finally, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that the federal program is being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations—The Office should: 1. Ensure it performs required monitoring of its subrecipients and their compliance with the award terms and program requirements by following its established policies and procedures to assess the risk of each subrecipient’s noncompliance annually and carry out monitoring activities based on those risk assessments such as reviewing financial and performance reports, providing training or technical assistance on program-related matters, and performing on site reviews, selective audits, and/or other monitoring procedures. 2. Continue to assess its resources, such as staffing, to perform required risk assessments and monitoring procedures to comply with the award terms and program requirements. 3. Work with the federal agency and the subrecipients to resolve the $1,903,858 of program monies that may have been spent in violation of its federal award terms and that may need to be returned to the federal agency.2 The State’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year findings 2022-104 (GEER) and 2022-106 (SLFRF) and were initially reported in fiscal years 2021 (GEER) and 2022 (SLFRF). 1 The Office reported during fiscal year 2024 it began performing missing risk assessments for subrecipients awarded monies during fiscal years 2022 and 2023 that were not completed by June 30, 2023, and is currently conducting additional onsite monitoring or desk reviews based on those results. As of the report date, December 17, 2024, the Office identified and reported to us approximately $1,903,858 of expenditures for 3 SLFRF program subrecipients that may not have been spent in accordance with program requirements. Since the Office is still performing monitoring procedures for subaward monies spent during fiscal year 2023, there may be additional questioned costs that the Office has not identified. 2 Federal Uniform Guidance requires federal awarding agencies to follow up on audit findings and issue a management decision to ensure the recipient, the Office, takes appropriate and timely corrective action (2 CFR §200.513[c]). Further, it requires that federal awarding agencies’ management decisions clearly state whether or not the audit finding is sustained, the reasons for the decision, and the expected auditee action to repay disallowed costs, make financial adjustments, or take other action, as directed by the federal awarding agencies (2 CFR §200.521). 3 Arizona Auditor General. (2023). State of Arizona June 30, 2022, Single Audit Report. Phoenix, AZ. Retrieved 08/13/2024 from https://www.azauditor.gov/sites/default/files/2024-01/StateOfArizonaJune30_2022SingleAudit.pdf
Assistance Listings number and name: 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds (SLFRF) Award number and year: None Federal agency: U.S. Department of the Treasury Questioned costs: $1,903,858 Assistance Listing number and name: 84.425C COVID-19 Education Stabilization Fund – Governor’s Emergency Education Relief (GEER) Fund Award numbers and years: S425C200052, June 2, 2020 through September 30, 2022; S425C210052, January 8, 2021 through September 30, 2023 Federal agency: U.S. Department of Education Questioned costs: Unknown Compliance requirement: Subrecipient monitoring Condition—The Governor’s Office of Strategic Planning and Budgeting (Office) awarded $135.1 million to 334 SLFRF program subrecipients and $10.2 million to 10 GEER program subrecipients during fiscal year 2023, or 88 percent and 98 percent, respectively, of each of the Office’s federal program expenditures, but did not perform all required risk assessments to assess whether its monitoring procedures were sufficient to evaluate whether subrecipients used program monies in accordance with the award terms and program requirements. Specifically, risk assessments were not performed for 37 of 42 SLFRF program subrecipients and 5 of 5 GEER program subrecipients tested. Effect—The Office’s delay in performing required risk assessments did not allow the Office to properly design and prioritize its monitoring efforts, resulting in the Office not timely identifying questioned costs of approximately $1,903,858 for 3 SLFRF program subrecipients that may not have been spent in accordance with program requirements.1 The Office identified several of these questioned costs as potentially inappropriate and has forwarded this information to the Attorney General’s Office for further review. As a result, the Office may be required to return these monies to the federal agency in accordance with Uniform Guidance requirements.2 Further, if monies were spent inconsistent with program requirements, those who were intended to benefit from the program may not have received all the services or other benefits they otherwise would have received. Subrecipient program expenditures are not related to the revenue loss expenditure category. Cause—Office management reported that it hired additional staff in fiscal year 2023 to begin addressing issues noted in prior year findings 2022-104 and 2022-10 but had not done so in time to complete required risk assessments for the more than 300 SLFRF program and 10 GEER program subrecipients.3 Criteria—Federal regulation requires the Office to monitor subrecipients, which includes required monitoring procedures for assessing the risk of each subrecipient’s noncompliance and monitoring activities based on those risk assessments. This federal regulation also provides that monitoring procedures may include reviewing financial and performance reports, providing training or technical assistance on program-related matters, and performing on-site reviews, selective audits, and/or other monitoring procedures (2 CFR §200.332[b] and [e]). Further, Office policy requires an annual risk assessment of open, active subawards to determine which subawards will be selected for review and monitoring priority (Grants Management Manual – Grantor, Chapter 8 – Award Monitoring). Finally, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that the federal program is being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations—The Office should: 1. Ensure it performs required monitoring of its subrecipients and their compliance with the award terms and program requirements by following its established policies and procedures to assess the risk of each subrecipient’s noncompliance annually and carry out monitoring activities based on those risk assessments such as reviewing financial and performance reports, providing training or technical assistance on program-related matters, and performing on site reviews, selective audits, and/or other monitoring procedures. 2. Continue to assess its resources, such as staffing, to perform required risk assessments and monitoring procedures to comply with the award terms and program requirements. 3. Work with the federal agency and the subrecipients to resolve the $1,903,858 of program monies that may have been spent in violation of its federal award terms and that may need to be returned to the federal agency.2 The State’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year findings 2022-104 (GEER) and 2022-106 (SLFRF) and were initially reported in fiscal years 2021 (GEER) and 2022 (SLFRF). 1 The Office reported during fiscal year 2024 it began performing missing risk assessments for subrecipients awarded monies during fiscal years 2022 and 2023 that were not completed by June 30, 2023, and is currently conducting additional onsite monitoring or desk reviews based on those results. As of the report date, December 17, 2024, the Office identified and reported to us approximately $1,903,858 of expenditures for 3 SLFRF program subrecipients that may not have been spent in accordance with program requirements. Since the Office is still performing monitoring procedures for subaward monies spent during fiscal year 2023, there may be additional questioned costs that the Office has not identified. 2 Federal Uniform Guidance requires federal awarding agencies to follow up on audit findings and issue a management decision to ensure the recipient, the Office, takes appropriate and timely corrective action (2 CFR §200.513[c]). Further, it requires that federal awarding agencies’ management decisions clearly state whether or not the audit finding is sustained, the reasons for the decision, and the expected auditee action to repay disallowed costs, make financial adjustments, or take other action, as directed by the federal awarding agencies (2 CFR §200.521). 3 Arizona Auditor General. (2023). State of Arizona June 30, 2022, Single Audit Report. Phoenix, AZ. Retrieved 08/13/2024 from https://www.azauditor.gov/sites/default/files/2024-01/StateOfArizonaJune30_2022SingleAudit.pdf
Assistance Listings number and name: 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds (SLFRF) Award number and year: None Federal agency: U.S. Department of the Treasury Questioned costs: $1,903,858 Assistance Listing number and name: 84.425C COVID-19 Education Stabilization Fund – Governor’s Emergency Education Relief (GEER) Fund Award numbers and years: S425C200052, June 2, 2020 through September 30, 2022; S425C210052, January 8, 2021 through September 30, 2023 Federal agency: U.S. Department of Education Questioned costs: Unknown Compliance requirement: Subrecipient monitoring Condition—The Governor’s Office of Strategic Planning and Budgeting (Office) awarded $135.1 million to 334 SLFRF program subrecipients and $10.2 million to 10 GEER program subrecipients during fiscal year 2023, or 88 percent and 98 percent, respectively, of each of the Office’s federal program expenditures, but did not perform all required risk assessments to assess whether its monitoring procedures were sufficient to evaluate whether subrecipients used program monies in accordance with the award terms and program requirements. Specifically, risk assessments were not performed for 37 of 42 SLFRF program subrecipients and 5 of 5 GEER program subrecipients tested. Effect—The Office’s delay in performing required risk assessments did not allow the Office to properly design and prioritize its monitoring efforts, resulting in the Office not timely identifying questioned costs of approximately $1,903,858 for 3 SLFRF program subrecipients that may not have been spent in accordance with program requirements.1 The Office identified several of these questioned costs as potentially inappropriate and has forwarded this information to the Attorney General’s Office for further review. As a result, the Office may be required to return these monies to the federal agency in accordance with Uniform Guidance requirements.2 Further, if monies were spent inconsistent with program requirements, those who were intended to benefit from the program may not have received all the services or other benefits they otherwise would have received. Subrecipient program expenditures are not related to the revenue loss expenditure category. Cause—Office management reported that it hired additional staff in fiscal year 2023 to begin addressing issues noted in prior year findings 2022-104 and 2022-10 but had not done so in time to complete required risk assessments for the more than 300 SLFRF program and 10 GEER program subrecipients.3 Criteria—Federal regulation requires the Office to monitor subrecipients, which includes required monitoring procedures for assessing the risk of each subrecipient’s noncompliance and monitoring activities based on those risk assessments. This federal regulation also provides that monitoring procedures may include reviewing financial and performance reports, providing training or technical assistance on program-related matters, and performing on-site reviews, selective audits, and/or other monitoring procedures (2 CFR §200.332[b] and [e]). Further, Office policy requires an annual risk assessment of open, active subawards to determine which subawards will be selected for review and monitoring priority (Grants Management Manual – Grantor, Chapter 8 – Award Monitoring). Finally, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that the federal program is being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations—The Office should: 1. Ensure it performs required monitoring of its subrecipients and their compliance with the award terms and program requirements by following its established policies and procedures to assess the risk of each subrecipient’s noncompliance annually and carry out monitoring activities based on those risk assessments such as reviewing financial and performance reports, providing training or technical assistance on program-related matters, and performing on site reviews, selective audits, and/or other monitoring procedures. 2. Continue to assess its resources, such as staffing, to perform required risk assessments and monitoring procedures to comply with the award terms and program requirements. 3. Work with the federal agency and the subrecipients to resolve the $1,903,858 of program monies that may have been spent in violation of its federal award terms and that may need to be returned to the federal agency.2 The State’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year findings 2022-104 (GEER) and 2022-106 (SLFRF) and were initially reported in fiscal years 2021 (GEER) and 2022 (SLFRF). 1 The Office reported during fiscal year 2024 it began performing missing risk assessments for subrecipients awarded monies during fiscal years 2022 and 2023 that were not completed by June 30, 2023, and is currently conducting additional onsite monitoring or desk reviews based on those results. As of the report date, December 17, 2024, the Office identified and reported to us approximately $1,903,858 of expenditures for 3 SLFRF program subrecipients that may not have been spent in accordance with program requirements. Since the Office is still performing monitoring procedures for subaward monies spent during fiscal year 2023, there may be additional questioned costs that the Office has not identified. 2 Federal Uniform Guidance requires federal awarding agencies to follow up on audit findings and issue a management decision to ensure the recipient, the Office, takes appropriate and timely corrective action (2 CFR §200.513[c]). Further, it requires that federal awarding agencies’ management decisions clearly state whether or not the audit finding is sustained, the reasons for the decision, and the expected auditee action to repay disallowed costs, make financial adjustments, or take other action, as directed by the federal awarding agencies (2 CFR §200.521). 3 Arizona Auditor General. (2023). State of Arizona June 30, 2022, Single Audit Report. Phoenix, AZ. Retrieved 08/13/2024 from https://www.azauditor.gov/sites/default/files/2024-01/StateOfArizonaJune30_2022SingleAudit.pdf
Assistance Listings number and name: 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds (SLFRF) Award number and year: None Federal agency: U.S. Department of the Treasury Questioned costs: $1,903,858 Assistance Listing number and name: 84.425C COVID-19 Education Stabilization Fund – Governor’s Emergency Education Relief (GEER) Fund Award numbers and years: S425C200052, June 2, 2020 through September 30, 2022; S425C210052, January 8, 2021 through September 30, 2023 Federal agency: U.S. Department of Education Questioned costs: Unknown Compliance requirement: Subrecipient monitoring Condition—The Governor’s Office of Strategic Planning and Budgeting (Office) awarded $135.1 million to 334 SLFRF program subrecipients and $10.2 million to 10 GEER program subrecipients during fiscal year 2023, or 88 percent and 98 percent, respectively, of each of the Office’s federal program expenditures, but did not perform all required risk assessments to assess whether its monitoring procedures were sufficient to evaluate whether subrecipients used program monies in accordance with the award terms and program requirements. Specifically, risk assessments were not performed for 37 of 42 SLFRF program subrecipients and 5 of 5 GEER program subrecipients tested. Effect—The Office’s delay in performing required risk assessments did not allow the Office to properly design and prioritize its monitoring efforts, resulting in the Office not timely identifying questioned costs of approximately $1,903,858 for 3 SLFRF program subrecipients that may not have been spent in accordance with program requirements.1 The Office identified several of these questioned costs as potentially inappropriate and has forwarded this information to the Attorney General’s Office for further review. As a result, the Office may be required to return these monies to the federal agency in accordance with Uniform Guidance requirements.2 Further, if monies were spent inconsistent with program requirements, those who were intended to benefit from the program may not have received all the services or other benefits they otherwise would have received. Subrecipient program expenditures are not related to the revenue loss expenditure category. Cause—Office management reported that it hired additional staff in fiscal year 2023 to begin addressing issues noted in prior year findings 2022-104 and 2022-10 but had not done so in time to complete required risk assessments for the more than 300 SLFRF program and 10 GEER program subrecipients.3 Criteria—Federal regulation requires the Office to monitor subrecipients, which includes required monitoring procedures for assessing the risk of each subrecipient’s noncompliance and monitoring activities based on those risk assessments. This federal regulation also provides that monitoring procedures may include reviewing financial and performance reports, providing training or technical assistance on program-related matters, and performing on-site reviews, selective audits, and/or other monitoring procedures (2 CFR §200.332[b] and [e]). Further, Office policy requires an annual risk assessment of open, active subawards to determine which subawards will be selected for review and monitoring priority (Grants Management Manual – Grantor, Chapter 8 – Award Monitoring). Finally, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that the federal program is being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations—The Office should: 1. Ensure it performs required monitoring of its subrecipients and their compliance with the award terms and program requirements by following its established policies and procedures to assess the risk of each subrecipient’s noncompliance annually and carry out monitoring activities based on those risk assessments such as reviewing financial and performance reports, providing training or technical assistance on program-related matters, and performing on site reviews, selective audits, and/or other monitoring procedures. 2. Continue to assess its resources, such as staffing, to perform required risk assessments and monitoring procedures to comply with the award terms and program requirements. 3. Work with the federal agency and the subrecipients to resolve the $1,903,858 of program monies that may have been spent in violation of its federal award terms and that may need to be returned to the federal agency.2 The State’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year findings 2022-104 (GEER) and 2022-106 (SLFRF) and were initially reported in fiscal years 2021 (GEER) and 2022 (SLFRF). 1 The Office reported during fiscal year 2024 it began performing missing risk assessments for subrecipients awarded monies during fiscal years 2022 and 2023 that were not completed by June 30, 2023, and is currently conducting additional onsite monitoring or desk reviews based on those results. As of the report date, December 17, 2024, the Office identified and reported to us approximately $1,903,858 of expenditures for 3 SLFRF program subrecipients that may not have been spent in accordance with program requirements. Since the Office is still performing monitoring procedures for subaward monies spent during fiscal year 2023, there may be additional questioned costs that the Office has not identified. 2 Federal Uniform Guidance requires federal awarding agencies to follow up on audit findings and issue a management decision to ensure the recipient, the Office, takes appropriate and timely corrective action (2 CFR §200.513[c]). Further, it requires that federal awarding agencies’ management decisions clearly state whether or not the audit finding is sustained, the reasons for the decision, and the expected auditee action to repay disallowed costs, make financial adjustments, or take other action, as directed by the federal awarding agencies (2 CFR §200.521). 3 Arizona Auditor General. (2023). State of Arizona June 30, 2022, Single Audit Report. Phoenix, AZ. Retrieved 08/13/2024 from https://www.azauditor.gov/sites/default/files/2024-01/StateOfArizonaJune30_2022SingleAudit.pdf
Assistance Listings number and name: 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds (SLFRF) Award number and year: None Federal agency: U.S. Department of the Treasury Questioned costs: $1,903,858 Assistance Listing number and name: 84.425C COVID-19 Education Stabilization Fund – Governor’s Emergency Education Relief (GEER) Fund Award numbers and years: S425C200052, June 2, 2020 through September 30, 2022; S425C210052, January 8, 2021 through September 30, 2023 Federal agency: U.S. Department of Education Questioned costs: Unknown Compliance requirement: Subrecipient monitoring Condition—The Governor’s Office of Strategic Planning and Budgeting (Office) awarded $135.1 million to 334 SLFRF program subrecipients and $10.2 million to 10 GEER program subrecipients during fiscal year 2023, or 88 percent and 98 percent, respectively, of each of the Office’s federal program expenditures, but did not perform all required risk assessments to assess whether its monitoring procedures were sufficient to evaluate whether subrecipients used program monies in accordance with the award terms and program requirements. Specifically, risk assessments were not performed for 37 of 42 SLFRF program subrecipients and 5 of 5 GEER program subrecipients tested. Effect—The Office’s delay in performing required risk assessments did not allow the Office to properly design and prioritize its monitoring efforts, resulting in the Office not timely identifying questioned costs of approximately $1,903,858 for 3 SLFRF program subrecipients that may not have been spent in accordance with program requirements.1 The Office identified several of these questioned costs as potentially inappropriate and has forwarded this information to the Attorney General’s Office for further review. As a result, the Office may be required to return these monies to the federal agency in accordance with Uniform Guidance requirements.2 Further, if monies were spent inconsistent with program requirements, those who were intended to benefit from the program may not have received all the services or other benefits they otherwise would have received. Subrecipient program expenditures are not related to the revenue loss expenditure category. Cause—Office management reported that it hired additional staff in fiscal year 2023 to begin addressing issues noted in prior year findings 2022-104 and 2022-10 but had not done so in time to complete required risk assessments for the more than 300 SLFRF program and 10 GEER program subrecipients.3 Criteria—Federal regulation requires the Office to monitor subrecipients, which includes required monitoring procedures for assessing the risk of each subrecipient’s noncompliance and monitoring activities based on those risk assessments. This federal regulation also provides that monitoring procedures may include reviewing financial and performance reports, providing training or technical assistance on program-related matters, and performing on-site reviews, selective audits, and/or other monitoring procedures (2 CFR §200.332[b] and [e]). Further, Office policy requires an annual risk assessment of open, active subawards to determine which subawards will be selected for review and monitoring priority (Grants Management Manual – Grantor, Chapter 8 – Award Monitoring). Finally, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that the federal program is being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations—The Office should: 1. Ensure it performs required monitoring of its subrecipients and their compliance with the award terms and program requirements by following its established policies and procedures to assess the risk of each subrecipient’s noncompliance annually and carry out monitoring activities based on those risk assessments such as reviewing financial and performance reports, providing training or technical assistance on program-related matters, and performing on site reviews, selective audits, and/or other monitoring procedures. 2. Continue to assess its resources, such as staffing, to perform required risk assessments and monitoring procedures to comply with the award terms and program requirements. 3. Work with the federal agency and the subrecipients to resolve the $1,903,858 of program monies that may have been spent in violation of its federal award terms and that may need to be returned to the federal agency.2 The State’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year findings 2022-104 (GEER) and 2022-106 (SLFRF) and were initially reported in fiscal years 2021 (GEER) and 2022 (SLFRF). 1 The Office reported during fiscal year 2024 it began performing missing risk assessments for subrecipients awarded monies during fiscal years 2022 and 2023 that were not completed by June 30, 2023, and is currently conducting additional onsite monitoring or desk reviews based on those results. As of the report date, December 17, 2024, the Office identified and reported to us approximately $1,903,858 of expenditures for 3 SLFRF program subrecipients that may not have been spent in accordance with program requirements. Since the Office is still performing monitoring procedures for subaward monies spent during fiscal year 2023, there may be additional questioned costs that the Office has not identified. 2 Federal Uniform Guidance requires federal awarding agencies to follow up on audit findings and issue a management decision to ensure the recipient, the Office, takes appropriate and timely corrective action (2 CFR §200.513[c]). Further, it requires that federal awarding agencies’ management decisions clearly state whether or not the audit finding is sustained, the reasons for the decision, and the expected auditee action to repay disallowed costs, make financial adjustments, or take other action, as directed by the federal awarding agencies (2 CFR §200.521). 3 Arizona Auditor General. (2023). State of Arizona June 30, 2022, Single Audit Report. Phoenix, AZ. Retrieved 08/13/2024 from https://www.azauditor.gov/sites/default/files/2024-01/StateOfArizonaJune30_2022SingleAudit.pdf
Assistance Listings numbers and names: 14.231 Emergency Solutions Grant Program 14.231 COVID-19 - Emergency Solutions Grant Program Award numbers and years: E-20-DW-04-001, July 1, 2020 through September 30, 2022; E-21-DC-04-001, July 1, 2021 through September 30, 2023 Federal agency: U.S. Department of Housing and Urban Development Questioned costs: $1,820 Assistance Listings numbers and names: 93.558 Temporary Assistance for Needy Families 93.558 COVID-19 - Temporary Assistance for Needy Families Award numbers and years: 2201AZTANF, October 1, 2021 through September 30, 2022; 2301AZTANF, October 1, 2022 through September 30, 2023 Federal agency: U.S. Department of Health and Human Services Questioned costs: $10,330 Compliance requirement: Subrecipient monitoring Total questioned costs: $12,150 Condition—Contrary to federal regulations and its federal award terms, the Department of Economic Security (DES) reimbursed 1 nonprofit organization subrecipient for federal program costs totaling $12,150 during fiscal year 2023 that were unsupported, unallowable, and/or paid to the nonprofit organization’s principal officers or their immediate family member in violation of conflict-of-interest disclosure requirements. Specifically, we reviewed 14 reimbursements that included Emergency Solutions Grant Program (ESG) and Temporary Assistance for Needy Family (TANF) program costs totaling $26,120 and $65,730 for the year, respectively, and found that DES reimbursed the subrecipient: • $4,733 for financial and accounting services that were paid to 1 of the nonprofit organization’s principal officers, who served as the Treasurer, and their company, which was not disclosed as a conflict of interest to DES as required by DES’ contract with the subrecipient and federal regulations. Also, the subrecipient allocated these costs to other federal programs and nonfederal activities; however, DES did not verify that the allocation method the subrecipient used was reasonable or that the costs, as allocated, were allowed by the program’s requirements ($112 for ESG and $4,621 for TANF). • $7,417 for bookkeeping services that were not adequately supported by sufficiently detailed invoices and a signed, written contract having a specified price rate for the services and terms; therefore, we were unable to verify if the amounts paid were appropriate. Further, DES reimbursed the subrecipient for payments made to the Treasurer’s family member, whose bookkeeping services company was not disclosed as a conflict of interest to DES as required by federal regulations. Also, the subrecipient allocated these costs to other federal programs and nonfederal activities; however, DES did not verify that the allocation method the subrecipient used was reasonable or that the costs, as allocated, were allowed by the program’s requirements ($1,708 for ESG and $5,709 for TANF). Additionally, contrary to federal regulations, DES had not ensured that the subrecipient implemented competitive purchasing procedures when procuring the professional services described above, and the subrecipient was unable to provide documentation that it had competitively procured the services. ESG was not audited as a major federal program for the State’s fiscal year 2023 single audit; therefore, the scope of our review was not sufficient to determine whether DES or its subrecipients complied with all applicable federal requirements for this program. We audited the TANF program as a major federal program for the State’s fiscal year 2023 single audit, and we performed follow-up procedures to the review that we conducted during fiscal year 2022. During the audit, we became aware of the potentially noncompliant 14 reimbursements involving 1 of DES’ nonprofit subrecipients with which it partnered to carry out federal and State programs, including the Continuum of Care Program (Assistance Listings number 14.267), ESG, and TANF, which was audited as a major federal program for fiscal year 2023, as well as the State Housing Trust Fund. Our review of select reimbursements to this subrecipient resulted in similar findings for the federal Continuum of Care Program and the State Housing Trust Fund that are described in findings 2023-116 and 2023-06, respectively. Effect—DES’ reimbursing a nonprofit organization subrecipient for $12,150 of unallowable or unsupported costs and/or costs paid to the nonprofit organization’s principal officer or their immediate family member in violation of conflict-of-interest disclosure requirements resulted in those monies being unavailable to be spent for their intended purpose of providing housing assistance to those in need. Consequently, DES may be required to return these monies to the federal agencies in accordance with federal requirements.1 Cause—Although DES’ subrecipient monitoring policies and procedures did not require it to obtain from subrecipients documentation supporting charges for personal and contracted professional services to verify allowability when subrecipients requested reimbursement, the policies and procedures required an on-site monitoring visit once every 3 years for each subrecipient in which it reviews a sample of the subrecipient’s personal and professional services charges. However, DES had not performed an on-site monitoring visit of the nonprofit subrecipient since 2018 because it had not yet resumed all its subrecipient-monitoring activities, such as conducting on-site reviews and providing training and technical assistance, since suspending these activities during the COVID-19 pandemic during fiscal year 2020. In addition, DES had not properly assessed the subrecipient’s risk of noncompliance with its award contract and program requirements to determine the level of monitoring procedures it should put in place or training the subrecipient needed. For example, DES was unaware that the subrecipient had not informed it of a principal officer’s conflicts of interest so that it could ensure that the principal officer and their immediate family member were not involved in decision-making related to those conflicts and selectively reviewed the related costs and activities for compliance purposes. Criteria—Federal regulations require DES to monitor subrecipients and include required procedures for assessing the risk of each subrecipient’s noncompliance and implementing appropriate monitoring procedures to address those risk assessments; verifying single audits were conducted timely, if required; reviewing financial and performance reports; following up on and ensuring corrective action is taken on deficiencies that could potentially affect the program; and issuing management decisions on the results of audit findings or monitoring.2 Federal regulations provide that monitoring procedures DES may implement to address a subrecipient’s risk assessment include providing training or technical assistance on program-related matters and performing on-site reviews and selective audits of reimbursed costs.2 In addition, federal regulations require DES’ subrecipients to allocate allowable costs using a reasonable basis, to use competitive purchasing standards when procuring goods and services, and to disclose in writing to DES any potential conflicts of interest.3 Finally, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303 and 45 CFR §75.303). Recommendations—DES should: 1. Immediately stop reimbursing the nonprofit subrecipient for costs that are unsupported, unallowable, and/or paid to the nonprofit subrecipient’s principal officer or their immediate family member in violation of federal regulations and take appropriate enforcement actions in accordance with its subaward contract. 2. Update its written policies and procedures for reviewing and approving subrecipient reimbursement requests to include a process to ensure costs are adequately supported, allowable in accordance with program requirements, and approved by the appropriate level of management. 3. Train personnel responsible for reviewing and approving subrecipient reimbursement requests on how to identify costs that are unallowable under federal regulations. 4. Assess the risk of each subrecipient’s noncompliance and perform the appropriate monitoring procedures based on the assessed risk, such as providing training or technical assistance on program-related matters and performing on-site reviews and selective audits of reimbursed costs for allowability. 5. Ensure subrecipients allocate allowable costs using a reasonable basis, use competitive purchasing standards when procuring goods and services, and disclose in writing to DES any potential conflicts of interest. DES may need to provide training and technical assistance to subrecipients that address these compliance areas, including DES obtaining conflict-of-interest disclosures from subrecipients as part of the subaward contract, as an example, or otherwise establishing a communication mechanism for subrecipients to use as such conflicts arise. 6. Continue to work with the nonprofit subrecipient to resolve the $12,150 of unallowable costs, including recovering these monies from the subrecipient and assessing the continued need to use this subrecipient for services. 7. Work with the federal agencies to resolve the $12,150 of unallowable costs that it reimbursed, which may involve returning monies to the agencies. The State’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year findings 2022-114 (TANF) and 2022-115 (ESG) and was initially reported in fiscal year 2022. 1 Federal Uniform Guidance and U.S. Health and Human Services audit requirements require federal awarding agencies to follow up on audit findings and issue a management decision to ensure the recipient takes appropriate and timely corrective action (2 CFR §200.513[c] and 45 CFR §75.513[c]). Further, they require that federal awarding agencies’ management decisions clearly state whether or not the audit finding is sustained, the reasons for the decision, and the expected auditee action to repay disallowed costs, make financial adjustments, or take other action, as directed by the federal awarding agencies (2 CFR §200.521 and 45 CFR §75.521). 2 The applicable federal requirements related to subrecipient monitoring can be found in the Code of Federal Regulations at 2 CFR §§200.332, .339, and .521 and 45 CFR §§75.352, .371, and .521. 3 The applicable federal requirements related to allowable costs, competitive purchasing, and conflicts of interest can be found in the Code of Federal Regulations at 2 CFR §§200.112, .318-.327, and Subpart E; 24 CFR §578.95; and 45 CFR §§75.112, .326-.335, and Subpart E.
Assistance Listings numbers and names: 14.231 Emergency Solutions Grant Program 14.231 COVID-19 - Emergency Solutions Grant Program Award numbers and years: E-20-DW-04-001, July 1, 2020 through September 30, 2022; E-21-DC-04-001, July 1, 2021 through September 30, 2023 Federal agency: U.S. Department of Housing and Urban Development Questioned costs: $1,820 Assistance Listings numbers and names: 93.558 Temporary Assistance for Needy Families 93.558 COVID-19 - Temporary Assistance for Needy Families Award numbers and years: 2201AZTANF, October 1, 2021 through September 30, 2022; 2301AZTANF, October 1, 2022 through September 30, 2023 Federal agency: U.S. Department of Health and Human Services Questioned costs: $10,330 Compliance requirement: Subrecipient monitoring Total questioned costs: $12,150 Condition—Contrary to federal regulations and its federal award terms, the Department of Economic Security (DES) reimbursed 1 nonprofit organization subrecipient for federal program costs totaling $12,150 during fiscal year 2023 that were unsupported, unallowable, and/or paid to the nonprofit organization’s principal officers or their immediate family member in violation of conflict-of-interest disclosure requirements. Specifically, we reviewed 14 reimbursements that included Emergency Solutions Grant Program (ESG) and Temporary Assistance for Needy Family (TANF) program costs totaling $26,120 and $65,730 for the year, respectively, and found that DES reimbursed the subrecipient: • $4,733 for financial and accounting services that were paid to 1 of the nonprofit organization’s principal officers, who served as the Treasurer, and their company, which was not disclosed as a conflict of interest to DES as required by DES’ contract with the subrecipient and federal regulations. Also, the subrecipient allocated these costs to other federal programs and nonfederal activities; however, DES did not verify that the allocation method the subrecipient used was reasonable or that the costs, as allocated, were allowed by the program’s requirements ($112 for ESG and $4,621 for TANF). • $7,417 for bookkeeping services that were not adequately supported by sufficiently detailed invoices and a signed, written contract having a specified price rate for the services and terms; therefore, we were unable to verify if the amounts paid were appropriate. Further, DES reimbursed the subrecipient for payments made to the Treasurer’s family member, whose bookkeeping services company was not disclosed as a conflict of interest to DES as required by federal regulations. Also, the subrecipient allocated these costs to other federal programs and nonfederal activities; however, DES did not verify that the allocation method the subrecipient used was reasonable or that the costs, as allocated, were allowed by the program’s requirements ($1,708 for ESG and $5,709 for TANF). Additionally, contrary to federal regulations, DES had not ensured that the subrecipient implemented competitive purchasing procedures when procuring the professional services described above, and the subrecipient was unable to provide documentation that it had competitively procured the services. ESG was not audited as a major federal program for the State’s fiscal year 2023 single audit; therefore, the scope of our review was not sufficient to determine whether DES or its subrecipients complied with all applicable federal requirements for this program. We audited the TANF program as a major federal program for the State’s fiscal year 2023 single audit, and we performed follow-up procedures to the review that we conducted during fiscal year 2022. During the audit, we became aware of the potentially noncompliant 14 reimbursements involving 1 of DES’ nonprofit subrecipients with which it partnered to carry out federal and State programs, including the Continuum of Care Program (Assistance Listings number 14.267), ESG, and TANF, which was audited as a major federal program for fiscal year 2023, as well as the State Housing Trust Fund. Our review of select reimbursements to this subrecipient resulted in similar findings for the federal Continuum of Care Program and the State Housing Trust Fund that are described in findings 2023-116 and 2023-06, respectively. Effect—DES’ reimbursing a nonprofit organization subrecipient for $12,150 of unallowable or unsupported costs and/or costs paid to the nonprofit organization’s principal officer or their immediate family member in violation of conflict-of-interest disclosure requirements resulted in those monies being unavailable to be spent for their intended purpose of providing housing assistance to those in need. Consequently, DES may be required to return these monies to the federal agencies in accordance with federal requirements.1 Cause—Although DES’ subrecipient monitoring policies and procedures did not require it to obtain from subrecipients documentation supporting charges for personal and contracted professional services to verify allowability when subrecipients requested reimbursement, the policies and procedures required an on-site monitoring visit once every 3 years for each subrecipient in which it reviews a sample of the subrecipient’s personal and professional services charges. However, DES had not performed an on-site monitoring visit of the nonprofit subrecipient since 2018 because it had not yet resumed all its subrecipient-monitoring activities, such as conducting on-site reviews and providing training and technical assistance, since suspending these activities during the COVID-19 pandemic during fiscal year 2020. In addition, DES had not properly assessed the subrecipient’s risk of noncompliance with its award contract and program requirements to determine the level of monitoring procedures it should put in place or training the subrecipient needed. For example, DES was unaware that the subrecipient had not informed it of a principal officer’s conflicts of interest so that it could ensure that the principal officer and their immediate family member were not involved in decision-making related to those conflicts and selectively reviewed the related costs and activities for compliance purposes. Criteria—Federal regulations require DES to monitor subrecipients and include required procedures for assessing the risk of each subrecipient’s noncompliance and implementing appropriate monitoring procedures to address those risk assessments; verifying single audits were conducted timely, if required; reviewing financial and performance reports; following up on and ensuring corrective action is taken on deficiencies that could potentially affect the program; and issuing management decisions on the results of audit findings or monitoring.2 Federal regulations provide that monitoring procedures DES may implement to address a subrecipient’s risk assessment include providing training or technical assistance on program-related matters and performing on-site reviews and selective audits of reimbursed costs.2 In addition, federal regulations require DES’ subrecipients to allocate allowable costs using a reasonable basis, to use competitive purchasing standards when procuring goods and services, and to disclose in writing to DES any potential conflicts of interest.3 Finally, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303 and 45 CFR §75.303). Recommendations—DES should: 1. Immediately stop reimbursing the nonprofit subrecipient for costs that are unsupported, unallowable, and/or paid to the nonprofit subrecipient’s principal officer or their immediate family member in violation of federal regulations and take appropriate enforcement actions in accordance with its subaward contract. 2. Update its written policies and procedures for reviewing and approving subrecipient reimbursement requests to include a process to ensure costs are adequately supported, allowable in accordance with program requirements, and approved by the appropriate level of management. 3. Train personnel responsible for reviewing and approving subrecipient reimbursement requests on how to identify costs that are unallowable under federal regulations. 4. Assess the risk of each subrecipient’s noncompliance and perform the appropriate monitoring procedures based on the assessed risk, such as providing training or technical assistance on program-related matters and performing on-site reviews and selective audits of reimbursed costs for allowability. 5. Ensure subrecipients allocate allowable costs using a reasonable basis, use competitive purchasing standards when procuring goods and services, and disclose in writing to DES any potential conflicts of interest. DES may need to provide training and technical assistance to subrecipients that address these compliance areas, including DES obtaining conflict-of-interest disclosures from subrecipients as part of the subaward contract, as an example, or otherwise establishing a communication mechanism for subrecipients to use as such conflicts arise. 6. Continue to work with the nonprofit subrecipient to resolve the $12,150 of unallowable costs, including recovering these monies from the subrecipient and assessing the continued need to use this subrecipient for services. 7. Work with the federal agencies to resolve the $12,150 of unallowable costs that it reimbursed, which may involve returning monies to the agencies. The State’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year findings 2022-114 (TANF) and 2022-115 (ESG) and was initially reported in fiscal year 2022. 1 Federal Uniform Guidance and U.S. Health and Human Services audit requirements require federal awarding agencies to follow up on audit findings and issue a management decision to ensure the recipient takes appropriate and timely corrective action (2 CFR §200.513[c] and 45 CFR §75.513[c]). Further, they require that federal awarding agencies’ management decisions clearly state whether or not the audit finding is sustained, the reasons for the decision, and the expected auditee action to repay disallowed costs, make financial adjustments, or take other action, as directed by the federal awarding agencies (2 CFR §200.521 and 45 CFR §75.521). 2 The applicable federal requirements related to subrecipient monitoring can be found in the Code of Federal Regulations at 2 CFR §§200.332, .339, and .521 and 45 CFR §§75.352, .371, and .521. 3 The applicable federal requirements related to allowable costs, competitive purchasing, and conflicts of interest can be found in the Code of Federal Regulations at 2 CFR §§200.112, .318-.327, and Subpart E; 24 CFR §578.95; and 45 CFR §§75.112, .326-.335, and Subpart E.
DEPARTMENT OF EMPLOYMENT SECURITY SUBRECIPIENT MONITORING Material Weakness Immaterial Noncompliance 2023-011 Strengthen Controls to Ensure Compliance with Subrecipient Monitoring Requirements. ALN Number (s) 17.258, 17.259, 17.278 – Workforce Innovation and Opportunity Act Federal Award No. UI-34724-20-55-A-28 Questioned Costs N/A Criteria The Code of Federal Regulations (2 CFR 200.332(a)), states all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. The Code of Federal Regulations (2 CFR 200.332) also states that pass-through entities must: d) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: 1. The subrecipient's prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F - Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; 4. The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). e) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by § 200.521 Management decision. f) Verify that every subrecipient is audited as required by Subpart F - Audit Requirements of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501 Audit requirements. The Code of Federal Regulations (2 CFR 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 comply 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). Condition The Mississippi Department of Employment Security (MDES) was unable to provide documentation of subaward agreements and monitoring activities performed. Cause Internal controls were not sufficient to ensure that copies of subaward agreements were maintained and available for audit, nor that it maintained documentation of subrecipient monitoring activities performed. Effect Auditors were unable to verify that subawards were issued in accordance with Federal requirements nor that the subrecipients had been adequately monitored and were audited as required by Subpart F. Recommendation MDES should review and enhance internal controls and procedures to ensure that it maintains copies of all subaward agreements, that proper subrecipient monitoring is conducted, and that evaluation of independent audits is performed for all subrecipients. Copies of subawards and documentation of subrecipient monitoring activities should be readily available for audit. Repeat Finding Yes; 2022-023. Statistically Valid No.
DEPARTMENT OF EMPLOYMENT SECURITY SUBRECIPIENT MONITORING Material Weakness Immaterial Noncompliance 2023-011 Strengthen Controls to Ensure Compliance with Subrecipient Monitoring Requirements. ALN Number (s) 17.258, 17.259, 17.278 – Workforce Innovation and Opportunity Act Federal Award No. UI-34724-20-55-A-28 Questioned Costs N/A Criteria The Code of Federal Regulations (2 CFR 200.332(a)), states all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. The Code of Federal Regulations (2 CFR 200.332) also states that pass-through entities must: d) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: 1. The subrecipient's prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F - Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; 4. The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). e) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by § 200.521 Management decision. f) Verify that every subrecipient is audited as required by Subpart F - Audit Requirements of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501 Audit requirements. The Code of Federal Regulations (2 CFR 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 comply 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). Condition The Mississippi Department of Employment Security (MDES) was unable to provide documentation of subaward agreements and monitoring activities performed. Cause Internal controls were not sufficient to ensure that copies of subaward agreements were maintained and available for audit, nor that it maintained documentation of subrecipient monitoring activities performed. Effect Auditors were unable to verify that subawards were issued in accordance with Federal requirements nor that the subrecipients had been adequately monitored and were audited as required by Subpart F. Recommendation MDES should review and enhance internal controls and procedures to ensure that it maintains copies of all subaward agreements, that proper subrecipient monitoring is conducted, and that evaluation of independent audits is performed for all subrecipients. Copies of subawards and documentation of subrecipient monitoring activities should be readily available for audit. Repeat Finding Yes; 2022-023. Statistically Valid No.
DEPARTMENT OF EMPLOYMENT SECURITY SUBRECIPIENT MONITORING Material Weakness Immaterial Noncompliance 2023-011 Strengthen Controls to Ensure Compliance with Subrecipient Monitoring Requirements. ALN Number (s) 17.258, 17.259, 17.278 – Workforce Innovation and Opportunity Act Federal Award No. UI-34724-20-55-A-28 Questioned Costs N/A Criteria The Code of Federal Regulations (2 CFR 200.332(a)), states all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. The Code of Federal Regulations (2 CFR 200.332) also states that pass-through entities must: d) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: 1. The subrecipient's prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F - Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; 4. The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). e) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by § 200.521 Management decision. f) Verify that every subrecipient is audited as required by Subpart F - Audit Requirements of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501 Audit requirements. The Code of Federal Regulations (2 CFR 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 comply 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). Condition The Mississippi Department of Employment Security (MDES) was unable to provide documentation of subaward agreements and monitoring activities performed. Cause Internal controls were not sufficient to ensure that copies of subaward agreements were maintained and available for audit, nor that it maintained documentation of subrecipient monitoring activities performed. Effect Auditors were unable to verify that subawards were issued in accordance with Federal requirements nor that the subrecipients had been adequately monitored and were audited as required by Subpart F. Recommendation MDES should review and enhance internal controls and procedures to ensure that it maintains copies of all subaward agreements, that proper subrecipient monitoring is conducted, and that evaluation of independent audits is performed for all subrecipients. Copies of subawards and documentation of subrecipient monitoring activities should be readily available for audit. Repeat Finding Yes; 2022-023. Statistically Valid No.
Program: Housing Voucher Cluster Federal Financial Assistance Listing No.: 14.871, 14.879 Federal Agency: U.S. Department of Housing and Urban Development Passed-through: n/a – direct award Award Number and Year: CA131, 2022/2023 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: 2 CFR 200.331(a) establishes the required elements that the pass-through entity (County) must include in their subrecipient agreements. 2 CFR 200.331(b) establishes the requirement that the pass-through entity must evaluate the risk of noncompliance with Federal statutes, regulations, and terms and conditions of the program for each subaward for the purpose of determining the appropriate subrecipient monitoring activities. 2 CFR 200.331(d) and 2 CFR 200.331(e) establishes the requirement that the pass-through entity must monitor the activities of each subrecipient of program funds to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward and achieves performance goals. 2 CFR 200.331(d) requires that the monitoring activities must include: 1) Reviewing of financial and performance reports as required by the pass-through entity. 2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. 3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by §200.521 Management decision. Condition: In 1 out of 1 instance selected, we found that the subrecipient agreement did not contain the federal award identification elements required to be communicated by the County. We found that the County does have documented policies and procedures for the evaluation of the subrecipient’s risk of noncompliance and subrecipient monitoring procedures; however, the risk assessment was performed in November 2022, which was after the agreement was in effect for the fiscal year 2023, and the review of the risk assessment was not documented until March 2023. Based on the County’s policy for monitoring of the subrecipient based on the assessed level of risk, the County was required to obtain and review quarterly reports and perform a site visit. There was no documentation supporting the receipt, review, and results of the review of the quarterly reports. There was also no evidence of the review and communication of the results of the site visit to the subrecipient. Cause: The County was unable to finalize the revised subrecipient agreement prior to fiscal year 2023, the County department adopted the policies and procedures to perform the risk assessment after the beginning of fiscal year 2023, and the subrecipient monitoring policies and procedures do not require the department to document its review and results of monitoring procedures. Effect: The County did not include all the required elements in their subaward, did not perform a risk assessment prior to the fiscal year 2023 subaward, and did not document the results of the monitoring procedures performed over the subaward. Questioned Costs: None reported. Context/Sampling: We selected 100% of the County’s subrecipients of the program. Repeat Finding from Prior Year(s): Yes, prior year finding 2022-003. Recommendation: We recommend that the County continue to strengthen its policies and procedures over subrecipient monitoring to ensure that a risk assessment is completed prior to the start of the annual award and reviewed timely, and strengthen its policies and procedures to ensure that the results of monitoring procedures are documented and review. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Program: Housing Voucher Cluster Federal Financial Assistance Listing No.: 14.871, 14.879 Federal Agency: U.S. Department of Housing and Urban Development Passed-through: n/a – direct award Award Number and Year: CA131, 2022/2023 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: 2 CFR 200.331(a) establishes the required elements that the pass-through entity (County) must include in their subrecipient agreements. 2 CFR 200.331(b) establishes the requirement that the pass-through entity must evaluate the risk of noncompliance with Federal statutes, regulations, and terms and conditions of the program for each subaward for the purpose of determining the appropriate subrecipient monitoring activities. 2 CFR 200.331(d) and 2 CFR 200.331(e) establishes the requirement that the pass-through entity must monitor the activities of each subrecipient of program funds to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward and achieves performance goals. 2 CFR 200.331(d) requires that the monitoring activities must include: 1) Reviewing of financial and performance reports as required by the pass-through entity. 2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. 3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by §200.521 Management decision. Condition: In 1 out of 1 instance selected, we found that the subrecipient agreement did not contain the federal award identification elements required to be communicated by the County. We found that the County does have documented policies and procedures for the evaluation of the subrecipient’s risk of noncompliance and subrecipient monitoring procedures; however, the risk assessment was performed in November 2022, which was after the agreement was in effect for the fiscal year 2023, and the review of the risk assessment was not documented until March 2023. Based on the County’s policy for monitoring of the subrecipient based on the assessed level of risk, the County was required to obtain and review quarterly reports and perform a site visit. There was no documentation supporting the receipt, review, and results of the review of the quarterly reports. There was also no evidence of the review and communication of the results of the site visit to the subrecipient. Cause: The County was unable to finalize the revised subrecipient agreement prior to fiscal year 2023, the County department adopted the policies and procedures to perform the risk assessment after the beginning of fiscal year 2023, and the subrecipient monitoring policies and procedures do not require the department to document its review and results of monitoring procedures. Effect: The County did not include all the required elements in their subaward, did not perform a risk assessment prior to the fiscal year 2023 subaward, and did not document the results of the monitoring procedures performed over the subaward. Questioned Costs: None reported. Context/Sampling: We selected 100% of the County’s subrecipients of the program. Repeat Finding from Prior Year(s): Yes, prior year finding 2022-003. Recommendation: We recommend that the County continue to strengthen its policies and procedures over subrecipient monitoring to ensure that a risk assessment is completed prior to the start of the annual award and reviewed timely, and strengthen its policies and procedures to ensure that the results of monitoring procedures are documented and review. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Program: Highway Planning and Construction Federal Financial Assistance Listing No.: 20.205 Federal Agency: U.S. Department of Transportation Passed-through: California Department of Transportation Award Number and Year: 5923, 2022/2023 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria:2 CFR 200.331(a) establishes the required elements that the pass-through entity (County) must include in their subrecipient agreements. 2 CFR 200.331(b) establishes the requirement that the pass-through entity must evaluate the risk of noncompliance with Federal statutes, regulations, and terms and conditions of the program for each subaward for the purpose of determining the appropriate subrecipient monitoring activities. 2 CFR 200.331(d) and 2 CFR 200.331(e) establishes the requirement that the pass-through entity must monitor the activities of each subrecipient of program funds to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward and achieves performance goals. 2 CFR 200.331(d) requires that the monitoring activities must include: 1) Reviewing of financial and performance reports as required by the pass-through entity. 2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. 3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by §200.521 Management decision. 2 CRF 200.331(f) establishes the requirement for the pass-through entity to verify whether the subrecipient is subject to a single audit when the subrecipient’s expenditures are expected to exceed the threshold set forth in 2 CRF 200.501. Condition: In 1 out of 1 instance selected, we found that the subrecipient agreement did not contain the federal award identification elements required to be communicated by the County, no risk assessment was performed, and no subrecipient monitoring was performed. In this same instance, a documented review of whether the subrecipient was subject to a single audit was also not performed. We also found that the subrecipient did not reflect the expenditures of the subaward in its single audit in the period the expenditures were incurred. Cause: The County improperly identified the subrecipient as a contractor. The County did not perform an evaluation of the agreement to determine whether the vendor was a contractor or a subrecipient. Effect: The County did not comply with the subrecipient monitoring compliance requirements. Questioned Costs: None reported. Context/Sampling: We selected 100% of the County’s subrecipients of the program. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the County establish procedures to determine whether agreements represent a contractor or a subrecipient arrangement. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Reference Number: 2023-009 Category of Finding: Subrecipient Monitoring Type of Finding: Material Weakness and Material Instance of Noncompliance State Administering Department: California Department of Public Health (Public Health) Assistance Listing Number: 93.323 Federal Program Title: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Federal Award Number and Year: NU50CK000539; 2021 Criteria Title 2 – Grants and Agreements. Subtitle A – Office of Management and Budget Guidance for Grants and Agreements. Chapter II – Office of Management and Budget Guidance. Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Subpart D – Post Federal Award Requirements. §200.303 Internal controls (2 CFR 200.303): The non-Federal entity must: (e) 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). Title 2 – Grants and Agreements. Subtitle A – Office of Management and Budget Guidance for Grants and Agreements. Chapter II – Office of Management and Budget Guidance. Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Subpart D – Post Federal Award Requirements. §200.332 Requirements for pass-through entities (2 CFR 200.332): All pass-through entities must: (a) Verify that the subrecipient is not excluded or disqualified in accordance with §180.300. Verification methods are provided in §180.300, which include confirming in SAM.gov that a potential subrecipient is not suspended, debarred, or otherwise excluded from receiving Federal funds. (b) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. (1) Federal award identification. (i) Subrecipient name (which must match the name associated with its unique entity identifier); (ii) Subrecipient’s unique entity identifier; (iii) Federal Award Identification Number (FAIN); (iv) Federal Award Date (see the definition of Federal award date in § 200.1 of this part) of award to the recipient by the Federal agency; (v) Subaward Period of Performance Start and End Date; (vi) Subaward Budget Period Start and End Date; (vii) Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; (viii) Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; (ix) Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; (x) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); (xi) Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; (xii) Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; (xiii) Identification of whether the award is R&D; and (xiv) Indirect cost rate for the Federal award (including if the de minimis rate is charged) per §200.414. (c) Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraphs (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards: (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with Subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency). (e) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. (3) Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by §200.521. (4) The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving cross-cutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the passthrough entity may rely on the subrecipient’s cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section §200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. (f) Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient’s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in §200.501. (g) Consider whether the results of the subrecipient’s audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity’s own records. Condition Public Health did not establish a formal risk assessment process over its subrecipients of federal awards by which to determine the frequency and extent of subrecipient monitoring to be performed. While Public Health received reimbursement invoices from subrecipients, there did not appear to be other financial or programmatic monitoring to verify subrecipients complied with applicable requirements. In addition, Public Health did not obtain supporting documentation for any expenditures invoiced by the subrecipients. Follow-up monitoring for subrecipients with no single audit reports did not appear to be performed. On-site monitoring visits were not completed. Public Health was unable to provide evidence that suspension and debarment status of subrecipients was checked prior to entering into subaward. Public Health used a Department Allocation Letter (DAL) for the COVID-19 program instead of an agreement or contract for the subaward to subrecipients. Certain required information for the subaward federal award information such as Assistance Listings number and Title and Federal Award Identification Number (FAIN) were not clearly identified in the DAL. Identification as a Repeat Finding Finding 2022-011 was reported in the immediate prior year. Cause Procedures to perform the required subrecipient monitoring were not established nor did Public Health perform an appropriate level of monitoring. Effect By not properly evaluating the risk of noncompliance, Public Health may inadvertently award grant funds to subrecipients who lack the necessary mechanisms or understanding to comply with federal statutes. This increases the likelihood of noncompliance arising during the performance of the grant-funded activities. Furthermore, failure to obtain and review single audit reports increases the risk of not properly identifying subrecipient program control weaknesses, noncompliance and performing sufficient follow-up on any subrecipient corrective action. Questioned Costs No questioned costs were identified. Context Disbursements to subrecipients for the ELC totaled $282,954,398, or 49% of total reported program expenditures. Recommendation Public Health should establish and document formal procedures for conducting risk assessments of subrecipient funding, including criteria for evaluating organizational capacity, financial stability, compliance history, and programmatic capabilities. Public Health should also develop and implement procedures outlining the process for obtaining single audit reports from subrecipients. Furthermore, a monitoring mechanism should be implemented to track compliance with the single audit mandate among subrecipients, including regular follow-ups and documentation of communication efforts. Public Health should ensure every subaward includes all requirements imposed on the subrecipient so that the federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the federal award. Views of Responsible Officials and Corrective Action Plan Management’s response is reported in “Management’s Response and Corrective Action Plan” included in a separate section at the end of this report.
Reference Number: 2023-012 Category of Finding: Subrecipient Monitoring Type of Finding: Material Weakness and Material Instance of Noncompliance State Administering Department: California Department of Social Services Assistance Listing Number: 93.575, 93.596 Federal Program Title: Child Care and Development Block Grant, Child Care Mandatory and Matching Funds of the Child Care and Development Fund (part of the Child Care and Development Fund Cluster) Federal Award Numbers and Years: 2101CACCDF; 2021 2101CACCC5; 2021 2234CACCDF; 2022 2234CACCDD; 2022 Criteria Title 2 – Grants and Agreements. Subtitle A – Office of Management and Budget Guidance for Grants and Agreements. Chapter II – Office of Management and Budget Guidance. Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Subpart D – Post Federal Award Requirements. Standards for Financial and Program Management. §200.303 Internal controls (2 CFR 200.303): The non-Federal entity must: (c) 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). Title 2 – Grants and Agreements. Subtitle A – Office of Management and Budget Guidance for Grants and Agreements. Chapter II – Office of Management and Budget Guidance. Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Subpart D – Post Federal Award Requirements. Subrecipient Monitoring and Management. §200.332 Requirements for pass-through entities (2 CFR 200.332): A pass-through entity must: (c) Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency). (e) Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports. (2) Ensure that the subrecipient takes corrective action on all significant developments that negatively affect the subaward. Significant developments include Single Audit findings related to the subaward, other audit findings, site visits, and written notifications from a subrecipient of adverse conditions which will impact their ability to meet the milestones or the objectives of a subaward. When significant developments negatively impact the subaward, a subrecipient must provide the pass-through entity with information on their plan for corrective action and any assistance needed to resolve the situation. (3) Issue a management decision for audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by §200.521. (4) Resolve audit findings specifically related to the subaward. However, the pass-through entity is not responsible for resolving cross-cutting audit findings that apply to the subaward and other Federal awards or subawards. If a subrecipient has a current Single Audit report and has not been excluded from receiving Federal funding (meaning, has not been debarred or suspended), the pass-through entity may rely on the subrecipient’s cognizant agency for audit or oversight agency for audit to perform audit follow-up and make management decisions related to cross-cutting audit findings in accordance with section §200.513(a)(4)(viii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. California Code of Regulations. Title 5 Education. § 18023. Compliance Reviews of Contractors. (b) At least once every three (3) years and as resources permit, the California Department of Education shall conduct reviews at the contractor's office(s) and operating facility(ies) to determine the contractor's compliance with applicable laws, regulations or contractual provisions. Child Care and Development Fund (CCDF) Plan for State/Territory California FFY 2022-24, Amendment 4. Chapter 8 Ensure Grantee Program Integrity and Accountability. 8.1 Internal Controls and Accountability Measures to Help Ensure Program Integrity. 8.1.1 Process to train about CCDF requirements and program integrity. States and territories are required to describe effective internal controls that are in place to ensure program integrity and accountability (98.68(a)), including processes to train child care providers and staff of the Lead Agency and other agencies engaged in the administration of CCDF about program requirements and integrity. v. Monitor and assess policy implementation on an ongoing basis. The Lead Agency conducts announced Categorical Program Monitoring (CPM)/Contract Monitoring Reviews (CMRs) for each contractor on a three- or four-year cycle for non-LEAs and LEAs respectively. The Lead Agency’s Governance and Administration Unit (GAU) conducts ongoing review of individual contractors by sampling the eligibility and need documentation in family files to estimate and reduce error rates. Additionally, the Lead Agency provides ongoing training and technical assistance to contractors in regional sessions, in one-on-one sessions, and/or in cluster with webinars or during face to-face presentations. These sessions address CCDF program administration, requirements, and integrity. Condition We selected 60 subrecipient contracts (14 local educational agency (LEA) contracts and 46 non-LEA contracts) from 50 subrecipient entities and tested compliance with subrecipient monitoring requirements. We noted the following: LEAs • 3 LEA contracts/contractors had no records for the receipt of a corrective action plan or notification of resolution for findings identified in monitoring reports. • 1 LEA contract/contractor did not have the quarterly fiscal reports available for review for the quarter selected for testing. Non-LEAs • 5 non-LEA contracts/contractors had no records available to demonstrate risk assessment of the contractor. • 4 non-LEA contracts/contractors had no record of on-site monitoring in over 5 years. • 7 non-LEA contracts/contractors had no records for the receipt of the corrective action plan or notification of resolution for findings identified in monitoring reports. • 5 non-LEA contracts/contractors did not have the quarterly fiscal reports available for review for the quarters selected for testing. The monitoring of the contractors’ single audit reports and follow-up on noted findings continued to be a shared responsibility between CDSS and the Department of Education (CDE) during fiscal year 2022-23. The transition of audit report monitoring responsibilities over LEAs receiving CCDF Cluster program funds is still in process and not yet centralized with CDSS. Furthermore, subrecipients continue to report the pass-through entity as CDE and not CDSS. Identification as a Repeat Finding This was not a repeat finding from the immediate prior year. Cause In fiscal year 2021, the administration of the CCDF Cluster program was transitioned from the California Department of Education (CDE) to CDSS. CDSS has been in the process of revising certain policies and procedures, including contractor monitoring. In addition, certain records related to CDE monitoring activities for the contracts selected were unavailable for review. Effect CDSS is at risk for contractor noncompliance if monitoring procedures are not properly designed or executed, and/or documents demonstrating monitoring are not maintained. Questioned Costs $175,631,433 of $332,931,906 sampled contract expenditures for fiscal year ended June 30, 2023. Context CDSS contractors may have multiple contracts with varying contract requirements. We selected one or more contracts from 50 different contractors for a total of 60 unique contracts representing $332,931,906 of expenditures incurred during the fiscal year ended June 30, 2023. The exceptions noted above represented 32 different contracts administered by 28 contractors and represented $175,613,433 or 52.7% of the total sampled contract expenditures. The sample was not a statistically valid sample. Recommendation To enhance the effectiveness of the annual risk assessment process, we recommend a thorough evaluation that focuses on the identification and inclusion of all subrecipients and defined risk criteria as mandated in 2 CFR 200.332. Furthermore, it is crucial to establish and document a transparent basis for risk profiling that directly correlates such profiles with compliance monitoring activities across fiscal, program, and single audit requirements. Furthermore, we recommend CDSS perform a comprehensive post-transition review to ensure all monitoring responsibilities transferred from CDE have been fully identified and assigned. This review should validate robust mechanisms are in place for the accurate documentation and proper retention of records. Views of Responsible Officials and Corrective Action Plan Management’s response is reported in “Management’s Response and Corrective Action Plan” included in a separate section at the end of this report.
Reference Number: 2023-012 Category of Finding: Subrecipient Monitoring Type of Finding: Material Weakness and Material Instance of Noncompliance State Administering Department: California Department of Social Services Assistance Listing Number: 93.575, 93.596 Federal Program Title: Child Care and Development Block Grant, Child Care Mandatory and Matching Funds of the Child Care and Development Fund (part of the Child Care and Development Fund Cluster) Federal Award Numbers and Years: 2101CACCDF; 2021 2101CACCC5; 2021 2234CACCDF; 2022 2234CACCDD; 2022 Criteria Title 2 – Grants and Agreements. Subtitle A – Office of Management and Budget Guidance for Grants and Agreements. Chapter II – Office of Management and Budget Guidance. Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Subpart D – Post Federal Award Requirements. Standards for Financial and Program Management. §200.303 Internal controls (2 CFR 200.303): The non-Federal entity must: (c) 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). Title 2 – Grants and Agreements. Subtitle A – Office of Management and Budget Guidance for Grants and Agreements. Chapter II – Office of Management and Budget Guidance. Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Subpart D – Post Federal Award Requirements. Subrecipient Monitoring and Management. §200.332 Requirements for pass-through entities (2 CFR 200.332): A pass-through entity must: (c) Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency). (e) Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports. (2) Ensure that the subrecipient takes corrective action on all significant developments that negatively affect the subaward. Significant developments include Single Audit findings related to the subaward, other audit findings, site visits, and written notifications from a subrecipient of adverse conditions which will impact their ability to meet the milestones or the objectives of a subaward. When significant developments negatively impact the subaward, a subrecipient must provide the pass-through entity with information on their plan for corrective action and any assistance needed to resolve the situation. (3) Issue a management decision for audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by §200.521. (4) Resolve audit findings specifically related to the subaward. However, the pass-through entity is not responsible for resolving cross-cutting audit findings that apply to the subaward and other Federal awards or subawards. If a subrecipient has a current Single Audit report and has not been excluded from receiving Federal funding (meaning, has not been debarred or suspended), the pass-through entity may rely on the subrecipient’s cognizant agency for audit or oversight agency for audit to perform audit follow-up and make management decisions related to cross-cutting audit findings in accordance with section §200.513(a)(4)(viii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. California Code of Regulations. Title 5 Education. § 18023. Compliance Reviews of Contractors. (b) At least once every three (3) years and as resources permit, the California Department of Education shall conduct reviews at the contractor's office(s) and operating facility(ies) to determine the contractor's compliance with applicable laws, regulations or contractual provisions. Child Care and Development Fund (CCDF) Plan for State/Territory California FFY 2022-24, Amendment 4. Chapter 8 Ensure Grantee Program Integrity and Accountability. 8.1 Internal Controls and Accountability Measures to Help Ensure Program Integrity. 8.1.1 Process to train about CCDF requirements and program integrity. States and territories are required to describe effective internal controls that are in place to ensure program integrity and accountability (98.68(a)), including processes to train child care providers and staff of the Lead Agency and other agencies engaged in the administration of CCDF about program requirements and integrity. v. Monitor and assess policy implementation on an ongoing basis. The Lead Agency conducts announced Categorical Program Monitoring (CPM)/Contract Monitoring Reviews (CMRs) for each contractor on a three- or four-year cycle for non-LEAs and LEAs respectively. The Lead Agency’s Governance and Administration Unit (GAU) conducts ongoing review of individual contractors by sampling the eligibility and need documentation in family files to estimate and reduce error rates. Additionally, the Lead Agency provides ongoing training and technical assistance to contractors in regional sessions, in one-on-one sessions, and/or in cluster with webinars or during face to-face presentations. These sessions address CCDF program administration, requirements, and integrity. Condition We selected 60 subrecipient contracts (14 local educational agency (LEA) contracts and 46 non-LEA contracts) from 50 subrecipient entities and tested compliance with subrecipient monitoring requirements. We noted the following: LEAs • 3 LEA contracts/contractors had no records for the receipt of a corrective action plan or notification of resolution for findings identified in monitoring reports. • 1 LEA contract/contractor did not have the quarterly fiscal reports available for review for the quarter selected for testing. Non-LEAs • 5 non-LEA contracts/contractors had no records available to demonstrate risk assessment of the contractor. • 4 non-LEA contracts/contractors had no record of on-site monitoring in over 5 years. • 7 non-LEA contracts/contractors had no records for the receipt of the corrective action plan or notification of resolution for findings identified in monitoring reports. • 5 non-LEA contracts/contractors did not have the quarterly fiscal reports available for review for the quarters selected for testing. The monitoring of the contractors’ single audit reports and follow-up on noted findings continued to be a shared responsibility between CDSS and the Department of Education (CDE) during fiscal year 2022-23. The transition of audit report monitoring responsibilities over LEAs receiving CCDF Cluster program funds is still in process and not yet centralized with CDSS. Furthermore, subrecipients continue to report the pass-through entity as CDE and not CDSS. Identification as a Repeat Finding This was not a repeat finding from the immediate prior year. Cause In fiscal year 2021, the administration of the CCDF Cluster program was transitioned from the California Department of Education (CDE) to CDSS. CDSS has been in the process of revising certain policies and procedures, including contractor monitoring. In addition, certain records related to CDE monitoring activities for the contracts selected were unavailable for review. Effect CDSS is at risk for contractor noncompliance if monitoring procedures are not properly designed or executed, and/or documents demonstrating monitoring are not maintained. Questioned Costs $175,631,433 of $332,931,906 sampled contract expenditures for fiscal year ended June 30, 2023. Context CDSS contractors may have multiple contracts with varying contract requirements. We selected one or more contracts from 50 different contractors for a total of 60 unique contracts representing $332,931,906 of expenditures incurred during the fiscal year ended June 30, 2023. The exceptions noted above represented 32 different contracts administered by 28 contractors and represented $175,613,433 or 52.7% of the total sampled contract expenditures. The sample was not a statistically valid sample. Recommendation To enhance the effectiveness of the annual risk assessment process, we recommend a thorough evaluation that focuses on the identification and inclusion of all subrecipients and defined risk criteria as mandated in 2 CFR 200.332. Furthermore, it is crucial to establish and document a transparent basis for risk profiling that directly correlates such profiles with compliance monitoring activities across fiscal, program, and single audit requirements. Furthermore, we recommend CDSS perform a comprehensive post-transition review to ensure all monitoring responsibilities transferred from CDE have been fully identified and assigned. This review should validate robust mechanisms are in place for the accurate documentation and proper retention of records. Views of Responsible Officials and Corrective Action Plan Management’s response is reported in “Management’s Response and Corrective Action Plan” included in a separate section at the end of this report.
Reference Number: 2023-012 Category of Finding: Subrecipient Monitoring Type of Finding: Material Weakness and Material Instance of Noncompliance State Administering Department: California Department of Social Services Assistance Listing Number: 93.575, 93.596 Federal Program Title: Child Care and Development Block Grant, Child Care Mandatory and Matching Funds of the Child Care and Development Fund (part of the Child Care and Development Fund Cluster) Federal Award Numbers and Years: 2101CACCDF; 2021 2101CACCC5; 2021 2234CACCDF; 2022 2234CACCDD; 2022 Criteria Title 2 – Grants and Agreements. Subtitle A – Office of Management and Budget Guidance for Grants and Agreements. Chapter II – Office of Management and Budget Guidance. Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Subpart D – Post Federal Award Requirements. Standards for Financial and Program Management. §200.303 Internal controls (2 CFR 200.303): The non-Federal entity must: (c) 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). Title 2 – Grants and Agreements. Subtitle A – Office of Management and Budget Guidance for Grants and Agreements. Chapter II – Office of Management and Budget Guidance. Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Subpart D – Post Federal Award Requirements. Subrecipient Monitoring and Management. §200.332 Requirements for pass-through entities (2 CFR 200.332): A pass-through entity must: (c) Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency). (e) Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports. (2) Ensure that the subrecipient takes corrective action on all significant developments that negatively affect the subaward. Significant developments include Single Audit findings related to the subaward, other audit findings, site visits, and written notifications from a subrecipient of adverse conditions which will impact their ability to meet the milestones or the objectives of a subaward. When significant developments negatively impact the subaward, a subrecipient must provide the pass-through entity with information on their plan for corrective action and any assistance needed to resolve the situation. (3) Issue a management decision for audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by §200.521. (4) Resolve audit findings specifically related to the subaward. However, the pass-through entity is not responsible for resolving cross-cutting audit findings that apply to the subaward and other Federal awards or subawards. If a subrecipient has a current Single Audit report and has not been excluded from receiving Federal funding (meaning, has not been debarred or suspended), the pass-through entity may rely on the subrecipient’s cognizant agency for audit or oversight agency for audit to perform audit follow-up and make management decisions related to cross-cutting audit findings in accordance with section §200.513(a)(4)(viii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. California Code of Regulations. Title 5 Education. § 18023. Compliance Reviews of Contractors. (b) At least once every three (3) years and as resources permit, the California Department of Education shall conduct reviews at the contractor's office(s) and operating facility(ies) to determine the contractor's compliance with applicable laws, regulations or contractual provisions. Child Care and Development Fund (CCDF) Plan for State/Territory California FFY 2022-24, Amendment 4. Chapter 8 Ensure Grantee Program Integrity and Accountability. 8.1 Internal Controls and Accountability Measures to Help Ensure Program Integrity. 8.1.1 Process to train about CCDF requirements and program integrity. States and territories are required to describe effective internal controls that are in place to ensure program integrity and accountability (98.68(a)), including processes to train child care providers and staff of the Lead Agency and other agencies engaged in the administration of CCDF about program requirements and integrity. v. Monitor and assess policy implementation on an ongoing basis. The Lead Agency conducts announced Categorical Program Monitoring (CPM)/Contract Monitoring Reviews (CMRs) for each contractor on a three- or four-year cycle for non-LEAs and LEAs respectively. The Lead Agency’s Governance and Administration Unit (GAU) conducts ongoing review of individual contractors by sampling the eligibility and need documentation in family files to estimate and reduce error rates. Additionally, the Lead Agency provides ongoing training and technical assistance to contractors in regional sessions, in one-on-one sessions, and/or in cluster with webinars or during face to-face presentations. These sessions address CCDF program administration, requirements, and integrity. Condition We selected 60 subrecipient contracts (14 local educational agency (LEA) contracts and 46 non-LEA contracts) from 50 subrecipient entities and tested compliance with subrecipient monitoring requirements. We noted the following: LEAs • 3 LEA contracts/contractors had no records for the receipt of a corrective action plan or notification of resolution for findings identified in monitoring reports. • 1 LEA contract/contractor did not have the quarterly fiscal reports available for review for the quarter selected for testing. Non-LEAs • 5 non-LEA contracts/contractors had no records available to demonstrate risk assessment of the contractor. • 4 non-LEA contracts/contractors had no record of on-site monitoring in over 5 years. • 7 non-LEA contracts/contractors had no records for the receipt of the corrective action plan or notification of resolution for findings identified in monitoring reports. • 5 non-LEA contracts/contractors did not have the quarterly fiscal reports available for review for the quarters selected for testing. The monitoring of the contractors’ single audit reports and follow-up on noted findings continued to be a shared responsibility between CDSS and the Department of Education (CDE) during fiscal year 2022-23. The transition of audit report monitoring responsibilities over LEAs receiving CCDF Cluster program funds is still in process and not yet centralized with CDSS. Furthermore, subrecipients continue to report the pass-through entity as CDE and not CDSS. Identification as a Repeat Finding This was not a repeat finding from the immediate prior year. Cause In fiscal year 2021, the administration of the CCDF Cluster program was transitioned from the California Department of Education (CDE) to CDSS. CDSS has been in the process of revising certain policies and procedures, including contractor monitoring. In addition, certain records related to CDE monitoring activities for the contracts selected were unavailable for review. Effect CDSS is at risk for contractor noncompliance if monitoring procedures are not properly designed or executed, and/or documents demonstrating monitoring are not maintained. Questioned Costs $175,631,433 of $332,931,906 sampled contract expenditures for fiscal year ended June 30, 2023. Context CDSS contractors may have multiple contracts with varying contract requirements. We selected one or more contracts from 50 different contractors for a total of 60 unique contracts representing $332,931,906 of expenditures incurred during the fiscal year ended June 30, 2023. The exceptions noted above represented 32 different contracts administered by 28 contractors and represented $175,613,433 or 52.7% of the total sampled contract expenditures. The sample was not a statistically valid sample. Recommendation To enhance the effectiveness of the annual risk assessment process, we recommend a thorough evaluation that focuses on the identification and inclusion of all subrecipients and defined risk criteria as mandated in 2 CFR 200.332. Furthermore, it is crucial to establish and document a transparent basis for risk profiling that directly correlates such profiles with compliance monitoring activities across fiscal, program, and single audit requirements. Furthermore, we recommend CDSS perform a comprehensive post-transition review to ensure all monitoring responsibilities transferred from CDE have been fully identified and assigned. This review should validate robust mechanisms are in place for the accurate documentation and proper retention of records. Views of Responsible Officials and Corrective Action Plan Management’s response is reported in “Management’s Response and Corrective Action Plan” included in a separate section at the end of this report.
FINDING REFERENCE NUMBER 2023-061 FEDERAL PROGRAMS (ALN – 93.558) TEMPORARY ASSISTANCE FOR NEEDY FAMILIES (TANF) U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES AWARD NUMBERS 2022G996117; 2023996117 (Federal Award Years: 2022 through 2023) ADMINISTRATION ADMINISTRATION FOR SOCIOECONOMIC DEVELOPMENT OF THE FAMILY (ADSEF, BY ITS SPANISH ACRONYM) COMPLIANCE REQUIREMENT SUBRECIPIENT MONITORING TYPE OF FINDING MATERIAL NONCOMPLIANCE AND MATERIAL WEAKNESS CRITERIA In accordance with 2 CFR 200.332, a pass-through entity must: (a) Verify that the subrecipient is not excluded or disqualified in accordance with § 180.300. Verification methods are provided in § 180.300, which include confirming in SAM.gov that a potential subrecipient is not suspended, debarred, or otherwise excluded from receiving Federal funds. (b) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the information provided below. A pass-through entity must provide the best available information when some of the information below is unavailable. A pass-through entity must provide the unavailable information when it is obtained. Required information includes: (1) Federal award identification. (i) Subrecipient's name (must match the name associated with its unique entity identifier); (ii) Subrecipient's unique entity identifier; (iii) Federal Award Identification Number (FAIN); (iv) Federal Award Date; (v) Subaward Period of Performance Start and End Date; (vi) Subaward Budget Period Start and End Date; (vii) Amount of Federal Funds Obligated in the subaward; (viii) Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity, including the current financial obligation; (ix) Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; (x) Federal award project description, as required by the Federal Funding Accountability and Transparency Act (FFATA); (xi) Name of the Federal agency, pass-through entity, and contact information for awarding official of the pass-through entity; (xii) Assistance Listings title and number; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at the time of disbursement; (xiii) Identification of whether the Federal award is for research and development; and (xiv) Indirect cost rate for the Federal award (including if the de minimis rate is used in accordance with § 200.414). (2) All requirements of the subaward, including requirements imposed by Federal statutes, regulations, and the terms and conditions of the Federal award; (3) Any additional requirements that the pass-through entity imposes on the subrecipient for the pass-through entity to meet its responsibilities under the Federal award. This includes information and certifications (see § 200.415) required for submitting financial and performance reports that the pass-through entity must provide to the Federal agency; … (5) A requirement that the subrecipient permit the pass-through entity and auditors to access the subrecipient's records and financial statements for the pass-through entity to fulfill its monitoring requirements; and (6) Appropriate terms and conditions concerning the closeout of the subaward. (c) Evaluate each subrecipient's fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient's risk, a pass-through entity should consider the following: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency). (d) If appropriate, consider implementing specific conditions in a subaward as described in § 200.208 and notify the Federal agency of the specific conditions. (e) Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports. (2) Ensure that the subrecipient takes corrective action on all significant developments that negatively affect the subaward. Significant developments include Single Audit findings related to the subaward, other audit findings, site visits, and written notifications from a subrecipient of adverse conditions which will impact their ability to meet the milestones or the objectives of a subaward. When significant developments negatively impact the subaward, a subrecipient must provide the pass-through entity with information on their plan for corrective action and any assistance needed to resolve the situation. (3) Issue a management decision for audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by § 200.521. (4) Resolve audit findings specifically related to the subaward. However, the pass-through entity is not responsible for resolving cross-cutting audit findings that apply to the subaward and other Federal awards or subawards. If a subrecipient has a current Single Audit report and has not been excluded from receiving Federal funding (meaning, has not been debarred or suspended), the pass-through entity may rely on the subrecipient's cognizant agency for audit or oversight agency for audit to perform audit follow-up and make management decisions related to cross-cutting audit findings in accordance with section § 200.513(a)(4)(viii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. (f) Depending upon the pass-through entity's assessment of the risk posed by the subrecipient (as described in paragraph (c) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; (2) Performing site visits to review the subrecipient's program operations; and (3) Arranging for agreed-upon-procedures engagements as described in § 200.425. (g) Verify that a subrecipient is audited as required by subpart F of this part. (h) Consider whether the results of a subrecipient's audit, site visits, or other monitoring necessitate adjustments to the pass-through entity's records. (i) Consider taking enforcement action against noncompliant subrecipients as described in § 200.339 and in program regulations. STATEMENT OF CONDITION As part of our understanding of the program, program staff were interviewed regarding the existence of subrecipients. None of the staff interviewed identified any transactions involving subrecipients. However, in our testing of internal controls and compliance with the allowable costs/cost principles requirement, transactions were selected to assess compliance with this requirement. Upon receiving documentation from a contractor, we realized that the transactions with this supplier were in the capacity of a subrecipient. In addition, the SEFA submitted by the PRDF does not identify any transaction under a subrecipient related to this program. In the final draft of the SEFA submitted for audit procedures, ADSEF reported the amount of $2,411,184, which included all transactions related to preventive services. We examined four (4) vouchers related to these services; the contract, proposal and invoices do not indicate information related to subrecipients. QUESTIONED COSTS No questioned costs identified. PERSPECTIVE INFORMATION This is a systemic deficiency. The staff in charge of administering TANF funds were unaware of the factors required to properly identify subrecipient transactions. The total expenditure reflected in the database related to subrecipient activities totaled $686,052.17 for the audited fiscal year. After providing the requirements for a subrecipient, staff were interviewed again to verify whether other providers met the subrecipient requirements, but no other entities were identified. From our testing, we identified no other subrecipients. Although, in the final draft of the SEFA submitted for audit procedures, all expenditures related to preventive services were included as pass-through expenditures. STATEMENT OF CAUSE The staff in charge of administering the program were unaware of the factors that determine whether a contractor is a subrecipient or a contractor. ADSEF has not established an adequate procedures manual that demonstrates compliance with all requirements for subrecipient activities. POSSIBLE ASSERTED EFFECT ADSEF does not have internal controls related to the identification, management, and reporting of subrecipient activities. This situation prevents compliance with all compliance requirements related to subrecipient monitoring. This situation prevented the proper presentation of Federal expenditures incurred under this program in the SEFA or other financial reports required by Federal agencies. IDENTIFICATION OF REPEAT FINDING No reported as prior audit finding. RECOMMENDATIONS The PRDF must provide training to ADSEF personnel on the requirements and regulations related to subrecipient monitoring. We recommend that management establish internal controls and compliance measures that allow for the identification, reporting, and monitoring of subrecipient activities.
State Agency: Illinois Governor’s Office of Management and Budget (GOMB) Federal Agency: U.S. Department of Agriculture (USDA), U.S. Department of Justice (DOJ), U.S. Department of Labor (DOL), U.S. Department of Transportation (DOT), U.S. Department of the Treasury (TREAS), U.S. Department of Education (ED), U.S. Department of Health and Human Services (USDHHS) Program Name: Special Supplemental Nutrition Program for Women, Infants and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program, WIOA Cluster, Highway Planning and Construction, Emergency Rental Assistance Program, Homeowner Assistance Fund Program, Coronavirus State and Local Fiscal Recovery Funds, Title I Grants to Local Educational Agencies, Twenty-First Century Community Learning Centers, Supporting Effective Instruction State Grants, Education Stabilization Fund (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families (TANF), Child Support Enforcement, Low-Income Home Energy Assistance Program, Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant, Block Grants for Prevention and Treatment of Substance Abuse ALN and Program Expenditures 10.557 ($168,740,425), 10.558 ($156,353,139), 16.575 ($78,196,419), 17.258/17.259/17.278 ($141,177,677), 20.205 ($1,932,300,419), 21.023 ($179,355,381), 21.026 ($177,107,928), 21.027 ($2,804,581,453), 84.010A ($704,235,726), 84.287 ($77,436,583),84.367A ($76,537,613), 84.425 ($2,227,152,891), 93.323 ($174,636,052), 93.558 ($578,867,422), 93.563 ($131,300,355), 93.568 ($288,503,657), 93.575/93.596 ($783,907,069), 93.667 ($57,147,970), 93.959 ($101,011,200) Award Numbers: Various – see table of award numbers Federal Award Year: Various – see table of award numbers Questioned Costs: None Finding 2023-002: Inadequate Monitoring of Subrecipient Single Audit Reviews Compliance Requirement: Subrecipient Monitoring Condition Found: The State of Illinois did not establish adequate controls to monitor the completion and documentation of the review single audit reports for its subrecipients of the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program (CVA), WIOA Cluster (WIOA), Highway and Planning Construction (Highway), Emergency Rental Assistance Program (ERAP), Homeowner Assistance Fund Program (HAF), Coronavirus State and Local Fiscal Recovery Funds (SLFRF), Twenty-First Century Community Learning Centers (Twenty-First), Title I Grants to Local Education Agencies (Title I), Supporting Effective Instruction State Grants (SEISG), Education Stabilization Funds (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families Cluster (TANF), Child Support Enforcement (CSE), Low-Income Home Energy Assistance Program (LIHEAP), Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant (SSBG), and Block Grants for Prevention and Treatment of Substance Abuse (SAPT) in the State's Grant Accountability and Transparency Act (GATA) Audit Report Review Management System (ARRMS). The State of Illinois established the Grant Accountability Transparency Unit (GATU) to implement the provisions of GATA on a centralized basis. GATU has established standardized reporting requirements for subrecipients of the various Federal programs administered by the State through its various departments. Subrecipients of the State are required to certify whether they expended more than $750,000 in federal awards during the fiscal year and submit their single audit reporting packages to the Federal Audit Clearinghouse (if required). GATU is then responsible for obtaining the single audit reporting package, verifying the report meets the single audit requirements, and assigning, to the applicable state agency, any findings attributable to amounts passed through to the subrecipient(s) by the State and working with program personnel to issue management decisions on findings. The State utilizes a contractor to perform the centralized functions of obtaining the single audit report, verifying the report meets the requirements, and assigning findings to the applicable State agency. During our testing of subrecipient single audit desk review files for our 2023 major programs, we noted instances where single audit desk reviews were still in process and had not been finalized within GATA ARRMS as of the date of our testing (October 7, 2024). One subrecipient in our sample for the WIC program had incomplete single audit reviews for fiscal years 2019 through 2022, despite the fact the State had obtained the single audit report from the Federal Audit Clearinghouse for each of these fiscal years. Upon further review of data contained within GATA ARRMS, we identified 669 single audit reviews were identified as incomplete in GATA ARRMS for grantees who: (1) reported expenditures under fiscal year 2023 major programs, (2) had an audit report with a FAC acceptance date between January 2, 2022 and January 3, 2023 (requiring the report to be reviewed during fiscal year 2023) and (3) were not sanctioned (placed on the Illinois Stop Payment List) by the State for noncompliance with reporting requirements. These 669 reviews were in varying stages of completion with the majority (608 audits) pending documentation supporting the issuance of a final completion letter by the cognizant agency. The remaining 61 audits (9.1%) were pending receipt of documentation, pending a review, or had another error requiring follow-up. These 669 audits included 323 audits (48.3%) with one or more findings potentially requiring a management decision to be issued. We noted the cognizant agencies for the 669 incomplete single audit reviews in GATA ARRMS were as follows: "See Table in the Audit Report". The 669 incomplete single audit reviews in GATA ARRMS pertained to subrecipients of the following major programs: "See Table in the Audit Report". While in many instances there was evidence the State agencies had completed the necessary procedures outside of GATA ARRMS, the purpose of GATA ARRMS is to reduce the duplication of effort across State agencies and to provide a single submission point for the State’s subrecipients. The lack of monitoring controls around this centralized process may result in noncompliance with subrecipient single audit desk review requirements. The State’s subrecipient expenditures under the federal programs for the year ended June 30, 2023 were as follows: "See Table in the Audit Report". Criteria or Requirement: According to 2 CFR 200.332(d), a pass-through entity is required to monitor the activities of subrecipients as necessary to ensure the federal awards are used for authorized purposes in compliance with laws, regulations, and the provisions of contracts or grant agreements and that performance goals are achieved. Further, 2 CFR 200.332(d)(3) and 2 CFR 200.521 state that a pass-through entity is required to issue a management decision on audit findings within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC) and ensure that the subrecipient takes timely and appropriate corrective action on all audit findings. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, 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. Effective internal controls should include implementing procedures to monitor whether single audit reports are reviewed, management decision letters are issued, and single audit desk review files are closed out in GATA ARRMS in a timely manner. Cause: In discussing these conditions with GOMB officials, management stated that the incompleteness of the State’s audit reviews in GATA ARRMS was due to oversight. Possible Asserted Effect: Failure to complete and document reviews of subrecipient single audit reports in GATA ARRMS in a timely manner may result in noncompliance with the State’s obligation as a pass-through entity to appropriately monitor its subrecipients. Repeat Finding: A similar finding was not reported in the prior year audit (Finding Code 2023-002). Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend GOMB establish procedures to monitor the completion and documentation of single audit report reviews in GATA ARRMS to ensure the State complies with its obligation as a pass-through entity. Views of GOMB Officials: GOMB agrees with the finding.
State Agency: Illinois Governor’s Office of Management and Budget (GOMB) Federal Agency: U.S. Department of Agriculture (USDA), U.S. Department of Justice (DOJ), U.S. Department of Labor (DOL), U.S. Department of Transportation (DOT), U.S. Department of the Treasury (TREAS), U.S. Department of Education (ED), U.S. Department of Health and Human Services (USDHHS) Program Name: Special Supplemental Nutrition Program for Women, Infants and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program, WIOA Cluster, Highway Planning and Construction, Emergency Rental Assistance Program, Homeowner Assistance Fund Program, Coronavirus State and Local Fiscal Recovery Funds, Title I Grants to Local Educational Agencies, Twenty-First Century Community Learning Centers, Supporting Effective Instruction State Grants, Education Stabilization Fund (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families (TANF), Child Support Enforcement, Low-Income Home Energy Assistance Program, Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant, Block Grants for Prevention and Treatment of Substance Abuse ALN and Program Expenditures 10.557 ($168,740,425), 10.558 ($156,353,139), 16.575 ($78,196,419), 17.258/17.259/17.278 ($141,177,677), 20.205 ($1,932,300,419), 21.023 ($179,355,381), 21.026 ($177,107,928), 21.027 ($2,804,581,453), 84.010A ($704,235,726), 84.287 ($77,436,583),84.367A ($76,537,613), 84.425 ($2,227,152,891), 93.323 ($174,636,052), 93.558 ($578,867,422), 93.563 ($131,300,355), 93.568 ($288,503,657), 93.575/93.596 ($783,907,069), 93.667 ($57,147,970), 93.959 ($101,011,200) Award Numbers: Various – see table of award numbers Federal Award Year: Various – see table of award numbers Questioned Costs: None Finding 2023-002: Inadequate Monitoring of Subrecipient Single Audit Reviews Compliance Requirement: Subrecipient Monitoring Condition Found: The State of Illinois did not establish adequate controls to monitor the completion and documentation of the review single audit reports for its subrecipients of the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program (CVA), WIOA Cluster (WIOA), Highway and Planning Construction (Highway), Emergency Rental Assistance Program (ERAP), Homeowner Assistance Fund Program (HAF), Coronavirus State and Local Fiscal Recovery Funds (SLFRF), Twenty-First Century Community Learning Centers (Twenty-First), Title I Grants to Local Education Agencies (Title I), Supporting Effective Instruction State Grants (SEISG), Education Stabilization Funds (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families Cluster (TANF), Child Support Enforcement (CSE), Low-Income Home Energy Assistance Program (LIHEAP), Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant (SSBG), and Block Grants for Prevention and Treatment of Substance Abuse (SAPT) in the State's Grant Accountability and Transparency Act (GATA) Audit Report Review Management System (ARRMS). The State of Illinois established the Grant Accountability Transparency Unit (GATU) to implement the provisions of GATA on a centralized basis. GATU has established standardized reporting requirements for subrecipients of the various Federal programs administered by the State through its various departments. Subrecipients of the State are required to certify whether they expended more than $750,000 in federal awards during the fiscal year and submit their single audit reporting packages to the Federal Audit Clearinghouse (if required). GATU is then responsible for obtaining the single audit reporting package, verifying the report meets the single audit requirements, and assigning, to the applicable state agency, any findings attributable to amounts passed through to the subrecipient(s) by the State and working with program personnel to issue management decisions on findings. The State utilizes a contractor to perform the centralized functions of obtaining the single audit report, verifying the report meets the requirements, and assigning findings to the applicable State agency. During our testing of subrecipient single audit desk review files for our 2023 major programs, we noted instances where single audit desk reviews were still in process and had not been finalized within GATA ARRMS as of the date of our testing (October 7, 2024). One subrecipient in our sample for the WIC program had incomplete single audit reviews for fiscal years 2019 through 2022, despite the fact the State had obtained the single audit report from the Federal Audit Clearinghouse for each of these fiscal years. Upon further review of data contained within GATA ARRMS, we identified 669 single audit reviews were identified as incomplete in GATA ARRMS for grantees who: (1) reported expenditures under fiscal year 2023 major programs, (2) had an audit report with a FAC acceptance date between January 2, 2022 and January 3, 2023 (requiring the report to be reviewed during fiscal year 2023) and (3) were not sanctioned (placed on the Illinois Stop Payment List) by the State for noncompliance with reporting requirements. These 669 reviews were in varying stages of completion with the majority (608 audits) pending documentation supporting the issuance of a final completion letter by the cognizant agency. The remaining 61 audits (9.1%) were pending receipt of documentation, pending a review, or had another error requiring follow-up. These 669 audits included 323 audits (48.3%) with one or more findings potentially requiring a management decision to be issued. We noted the cognizant agencies for the 669 incomplete single audit reviews in GATA ARRMS were as follows: "See Table in the Audit Report". The 669 incomplete single audit reviews in GATA ARRMS pertained to subrecipients of the following major programs: "See Table in the Audit Report". While in many instances there was evidence the State agencies had completed the necessary procedures outside of GATA ARRMS, the purpose of GATA ARRMS is to reduce the duplication of effort across State agencies and to provide a single submission point for the State’s subrecipients. The lack of monitoring controls around this centralized process may result in noncompliance with subrecipient single audit desk review requirements. The State’s subrecipient expenditures under the federal programs for the year ended June 30, 2023 were as follows: "See Table in the Audit Report". Criteria or Requirement: According to 2 CFR 200.332(d), a pass-through entity is required to monitor the activities of subrecipients as necessary to ensure the federal awards are used for authorized purposes in compliance with laws, regulations, and the provisions of contracts or grant agreements and that performance goals are achieved. Further, 2 CFR 200.332(d)(3) and 2 CFR 200.521 state that a pass-through entity is required to issue a management decision on audit findings within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC) and ensure that the subrecipient takes timely and appropriate corrective action on all audit findings. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, 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. Effective internal controls should include implementing procedures to monitor whether single audit reports are reviewed, management decision letters are issued, and single audit desk review files are closed out in GATA ARRMS in a timely manner. Cause: In discussing these conditions with GOMB officials, management stated that the incompleteness of the State’s audit reviews in GATA ARRMS was due to oversight. Possible Asserted Effect: Failure to complete and document reviews of subrecipient single audit reports in GATA ARRMS in a timely manner may result in noncompliance with the State’s obligation as a pass-through entity to appropriately monitor its subrecipients. Repeat Finding: A similar finding was not reported in the prior year audit (Finding Code 2023-002). Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend GOMB establish procedures to monitor the completion and documentation of single audit report reviews in GATA ARRMS to ensure the State complies with its obligation as a pass-through entity. Views of GOMB Officials: GOMB agrees with the finding.
State Agency: Illinois Governor’s Office of Management and Budget (GOMB) Federal Agency: U.S. Department of Agriculture (USDA), U.S. Department of Justice (DOJ), U.S. Department of Labor (DOL), U.S. Department of Transportation (DOT), U.S. Department of the Treasury (TREAS), U.S. Department of Education (ED), U.S. Department of Health and Human Services (USDHHS) Program Name: Special Supplemental Nutrition Program for Women, Infants and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program, WIOA Cluster, Highway Planning and Construction, Emergency Rental Assistance Program, Homeowner Assistance Fund Program, Coronavirus State and Local Fiscal Recovery Funds, Title I Grants to Local Educational Agencies, Twenty-First Century Community Learning Centers, Supporting Effective Instruction State Grants, Education Stabilization Fund (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families (TANF), Child Support Enforcement, Low-Income Home Energy Assistance Program, Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant, Block Grants for Prevention and Treatment of Substance Abuse ALN and Program Expenditures 10.557 ($168,740,425), 10.558 ($156,353,139), 16.575 ($78,196,419), 17.258/17.259/17.278 ($141,177,677), 20.205 ($1,932,300,419), 21.023 ($179,355,381), 21.026 ($177,107,928), 21.027 ($2,804,581,453), 84.010A ($704,235,726), 84.287 ($77,436,583),84.367A ($76,537,613), 84.425 ($2,227,152,891), 93.323 ($174,636,052), 93.558 ($578,867,422), 93.563 ($131,300,355), 93.568 ($288,503,657), 93.575/93.596 ($783,907,069), 93.667 ($57,147,970), 93.959 ($101,011,200) Award Numbers: Various – see table of award numbers Federal Award Year: Various – see table of award numbers Questioned Costs: None Finding 2023-002: Inadequate Monitoring of Subrecipient Single Audit Reviews Compliance Requirement: Subrecipient Monitoring Condition Found: The State of Illinois did not establish adequate controls to monitor the completion and documentation of the review single audit reports for its subrecipients of the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program (CVA), WIOA Cluster (WIOA), Highway and Planning Construction (Highway), Emergency Rental Assistance Program (ERAP), Homeowner Assistance Fund Program (HAF), Coronavirus State and Local Fiscal Recovery Funds (SLFRF), Twenty-First Century Community Learning Centers (Twenty-First), Title I Grants to Local Education Agencies (Title I), Supporting Effective Instruction State Grants (SEISG), Education Stabilization Funds (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families Cluster (TANF), Child Support Enforcement (CSE), Low-Income Home Energy Assistance Program (LIHEAP), Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant (SSBG), and Block Grants for Prevention and Treatment of Substance Abuse (SAPT) in the State's Grant Accountability and Transparency Act (GATA) Audit Report Review Management System (ARRMS). The State of Illinois established the Grant Accountability Transparency Unit (GATU) to implement the provisions of GATA on a centralized basis. GATU has established standardized reporting requirements for subrecipients of the various Federal programs administered by the State through its various departments. Subrecipients of the State are required to certify whether they expended more than $750,000 in federal awards during the fiscal year and submit their single audit reporting packages to the Federal Audit Clearinghouse (if required). GATU is then responsible for obtaining the single audit reporting package, verifying the report meets the single audit requirements, and assigning, to the applicable state agency, any findings attributable to amounts passed through to the subrecipient(s) by the State and working with program personnel to issue management decisions on findings. The State utilizes a contractor to perform the centralized functions of obtaining the single audit report, verifying the report meets the requirements, and assigning findings to the applicable State agency. During our testing of subrecipient single audit desk review files for our 2023 major programs, we noted instances where single audit desk reviews were still in process and had not been finalized within GATA ARRMS as of the date of our testing (October 7, 2024). One subrecipient in our sample for the WIC program had incomplete single audit reviews for fiscal years 2019 through 2022, despite the fact the State had obtained the single audit report from the Federal Audit Clearinghouse for each of these fiscal years. Upon further review of data contained within GATA ARRMS, we identified 669 single audit reviews were identified as incomplete in GATA ARRMS for grantees who: (1) reported expenditures under fiscal year 2023 major programs, (2) had an audit report with a FAC acceptance date between January 2, 2022 and January 3, 2023 (requiring the report to be reviewed during fiscal year 2023) and (3) were not sanctioned (placed on the Illinois Stop Payment List) by the State for noncompliance with reporting requirements. These 669 reviews were in varying stages of completion with the majority (608 audits) pending documentation supporting the issuance of a final completion letter by the cognizant agency. The remaining 61 audits (9.1%) were pending receipt of documentation, pending a review, or had another error requiring follow-up. These 669 audits included 323 audits (48.3%) with one or more findings potentially requiring a management decision to be issued. We noted the cognizant agencies for the 669 incomplete single audit reviews in GATA ARRMS were as follows: "See Table in the Audit Report". The 669 incomplete single audit reviews in GATA ARRMS pertained to subrecipients of the following major programs: "See Table in the Audit Report". While in many instances there was evidence the State agencies had completed the necessary procedures outside of GATA ARRMS, the purpose of GATA ARRMS is to reduce the duplication of effort across State agencies and to provide a single submission point for the State’s subrecipients. The lack of monitoring controls around this centralized process may result in noncompliance with subrecipient single audit desk review requirements. The State’s subrecipient expenditures under the federal programs for the year ended June 30, 2023 were as follows: "See Table in the Audit Report". Criteria or Requirement: According to 2 CFR 200.332(d), a pass-through entity is required to monitor the activities of subrecipients as necessary to ensure the federal awards are used for authorized purposes in compliance with laws, regulations, and the provisions of contracts or grant agreements and that performance goals are achieved. Further, 2 CFR 200.332(d)(3) and 2 CFR 200.521 state that a pass-through entity is required to issue a management decision on audit findings within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC) and ensure that the subrecipient takes timely and appropriate corrective action on all audit findings. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, 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. Effective internal controls should include implementing procedures to monitor whether single audit reports are reviewed, management decision letters are issued, and single audit desk review files are closed out in GATA ARRMS in a timely manner. Cause: In discussing these conditions with GOMB officials, management stated that the incompleteness of the State’s audit reviews in GATA ARRMS was due to oversight. Possible Asserted Effect: Failure to complete and document reviews of subrecipient single audit reports in GATA ARRMS in a timely manner may result in noncompliance with the State’s obligation as a pass-through entity to appropriately monitor its subrecipients. Repeat Finding: A similar finding was not reported in the prior year audit (Finding Code 2023-002). Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend GOMB establish procedures to monitor the completion and documentation of single audit report reviews in GATA ARRMS to ensure the State complies with its obligation as a pass-through entity. Views of GOMB Officials: GOMB agrees with the finding.
State Agency: Illinois Governor’s Office of Management and Budget (GOMB) Federal Agency: U.S. Department of Agriculture (USDA), U.S. Department of Justice (DOJ), U.S. Department of Labor (DOL), U.S. Department of Transportation (DOT), U.S. Department of the Treasury (TREAS), U.S. Department of Education (ED), U.S. Department of Health and Human Services (USDHHS) Program Name: Special Supplemental Nutrition Program for Women, Infants and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program, WIOA Cluster, Highway Planning and Construction, Emergency Rental Assistance Program, Homeowner Assistance Fund Program, Coronavirus State and Local Fiscal Recovery Funds, Title I Grants to Local Educational Agencies, Twenty-First Century Community Learning Centers, Supporting Effective Instruction State Grants, Education Stabilization Fund (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families (TANF), Child Support Enforcement, Low-Income Home Energy Assistance Program, Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant, Block Grants for Prevention and Treatment of Substance Abuse ALN and Program Expenditures 10.557 ($168,740,425), 10.558 ($156,353,139), 16.575 ($78,196,419), 17.258/17.259/17.278 ($141,177,677), 20.205 ($1,932,300,419), 21.023 ($179,355,381), 21.026 ($177,107,928), 21.027 ($2,804,581,453), 84.010A ($704,235,726), 84.287 ($77,436,583),84.367A ($76,537,613), 84.425 ($2,227,152,891), 93.323 ($174,636,052), 93.558 ($578,867,422), 93.563 ($131,300,355), 93.568 ($288,503,657), 93.575/93.596 ($783,907,069), 93.667 ($57,147,970), 93.959 ($101,011,200) Award Numbers: Various – see table of award numbers Federal Award Year: Various – see table of award numbers Questioned Costs: None Finding 2023-002: Inadequate Monitoring of Subrecipient Single Audit Reviews Compliance Requirement: Subrecipient Monitoring Condition Found: The State of Illinois did not establish adequate controls to monitor the completion and documentation of the review single audit reports for its subrecipients of the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program (CVA), WIOA Cluster (WIOA), Highway and Planning Construction (Highway), Emergency Rental Assistance Program (ERAP), Homeowner Assistance Fund Program (HAF), Coronavirus State and Local Fiscal Recovery Funds (SLFRF), Twenty-First Century Community Learning Centers (Twenty-First), Title I Grants to Local Education Agencies (Title I), Supporting Effective Instruction State Grants (SEISG), Education Stabilization Funds (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families Cluster (TANF), Child Support Enforcement (CSE), Low-Income Home Energy Assistance Program (LIHEAP), Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant (SSBG), and Block Grants for Prevention and Treatment of Substance Abuse (SAPT) in the State's Grant Accountability and Transparency Act (GATA) Audit Report Review Management System (ARRMS). The State of Illinois established the Grant Accountability Transparency Unit (GATU) to implement the provisions of GATA on a centralized basis. GATU has established standardized reporting requirements for subrecipients of the various Federal programs administered by the State through its various departments. Subrecipients of the State are required to certify whether they expended more than $750,000 in federal awards during the fiscal year and submit their single audit reporting packages to the Federal Audit Clearinghouse (if required). GATU is then responsible for obtaining the single audit reporting package, verifying the report meets the single audit requirements, and assigning, to the applicable state agency, any findings attributable to amounts passed through to the subrecipient(s) by the State and working with program personnel to issue management decisions on findings. The State utilizes a contractor to perform the centralized functions of obtaining the single audit report, verifying the report meets the requirements, and assigning findings to the applicable State agency. During our testing of subrecipient single audit desk review files for our 2023 major programs, we noted instances where single audit desk reviews were still in process and had not been finalized within GATA ARRMS as of the date of our testing (October 7, 2024). One subrecipient in our sample for the WIC program had incomplete single audit reviews for fiscal years 2019 through 2022, despite the fact the State had obtained the single audit report from the Federal Audit Clearinghouse for each of these fiscal years. Upon further review of data contained within GATA ARRMS, we identified 669 single audit reviews were identified as incomplete in GATA ARRMS for grantees who: (1) reported expenditures under fiscal year 2023 major programs, (2) had an audit report with a FAC acceptance date between January 2, 2022 and January 3, 2023 (requiring the report to be reviewed during fiscal year 2023) and (3) were not sanctioned (placed on the Illinois Stop Payment List) by the State for noncompliance with reporting requirements. These 669 reviews were in varying stages of completion with the majority (608 audits) pending documentation supporting the issuance of a final completion letter by the cognizant agency. The remaining 61 audits (9.1%) were pending receipt of documentation, pending a review, or had another error requiring follow-up. These 669 audits included 323 audits (48.3%) with one or more findings potentially requiring a management decision to be issued. We noted the cognizant agencies for the 669 incomplete single audit reviews in GATA ARRMS were as follows: "See Table in the Audit Report". The 669 incomplete single audit reviews in GATA ARRMS pertained to subrecipients of the following major programs: "See Table in the Audit Report". While in many instances there was evidence the State agencies had completed the necessary procedures outside of GATA ARRMS, the purpose of GATA ARRMS is to reduce the duplication of effort across State agencies and to provide a single submission point for the State’s subrecipients. The lack of monitoring controls around this centralized process may result in noncompliance with subrecipient single audit desk review requirements. The State’s subrecipient expenditures under the federal programs for the year ended June 30, 2023 were as follows: "See Table in the Audit Report". Criteria or Requirement: According to 2 CFR 200.332(d), a pass-through entity is required to monitor the activities of subrecipients as necessary to ensure the federal awards are used for authorized purposes in compliance with laws, regulations, and the provisions of contracts or grant agreements and that performance goals are achieved. Further, 2 CFR 200.332(d)(3) and 2 CFR 200.521 state that a pass-through entity is required to issue a management decision on audit findings within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC) and ensure that the subrecipient takes timely and appropriate corrective action on all audit findings. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, 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. Effective internal controls should include implementing procedures to monitor whether single audit reports are reviewed, management decision letters are issued, and single audit desk review files are closed out in GATA ARRMS in a timely manner. Cause: In discussing these conditions with GOMB officials, management stated that the incompleteness of the State’s audit reviews in GATA ARRMS was due to oversight. Possible Asserted Effect: Failure to complete and document reviews of subrecipient single audit reports in GATA ARRMS in a timely manner may result in noncompliance with the State’s obligation as a pass-through entity to appropriately monitor its subrecipients. Repeat Finding: A similar finding was not reported in the prior year audit (Finding Code 2023-002). Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend GOMB establish procedures to monitor the completion and documentation of single audit report reviews in GATA ARRMS to ensure the State complies with its obligation as a pass-through entity. Views of GOMB Officials: GOMB agrees with the finding.
State Agency: Illinois Governor’s Office of Management and Budget (GOMB) Federal Agency: U.S. Department of Agriculture (USDA), U.S. Department of Justice (DOJ), U.S. Department of Labor (DOL), U.S. Department of Transportation (DOT), U.S. Department of the Treasury (TREAS), U.S. Department of Education (ED), U.S. Department of Health and Human Services (USDHHS) Program Name: Special Supplemental Nutrition Program for Women, Infants and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program, WIOA Cluster, Highway Planning and Construction, Emergency Rental Assistance Program, Homeowner Assistance Fund Program, Coronavirus State and Local Fiscal Recovery Funds, Title I Grants to Local Educational Agencies, Twenty-First Century Community Learning Centers, Supporting Effective Instruction State Grants, Education Stabilization Fund (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families (TANF), Child Support Enforcement, Low-Income Home Energy Assistance Program, Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant, Block Grants for Prevention and Treatment of Substance Abuse ALN and Program Expenditures 10.557 ($168,740,425), 10.558 ($156,353,139), 16.575 ($78,196,419), 17.258/17.259/17.278 ($141,177,677), 20.205 ($1,932,300,419), 21.023 ($179,355,381), 21.026 ($177,107,928), 21.027 ($2,804,581,453), 84.010A ($704,235,726), 84.287 ($77,436,583),84.367A ($76,537,613), 84.425 ($2,227,152,891), 93.323 ($174,636,052), 93.558 ($578,867,422), 93.563 ($131,300,355), 93.568 ($288,503,657), 93.575/93.596 ($783,907,069), 93.667 ($57,147,970), 93.959 ($101,011,200) Award Numbers: Various – see table of award numbers Federal Award Year: Various – see table of award numbers Questioned Costs: None Finding 2023-002: Inadequate Monitoring of Subrecipient Single Audit Reviews Compliance Requirement: Subrecipient Monitoring Condition Found: The State of Illinois did not establish adequate controls to monitor the completion and documentation of the review single audit reports for its subrecipients of the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program (CVA), WIOA Cluster (WIOA), Highway and Planning Construction (Highway), Emergency Rental Assistance Program (ERAP), Homeowner Assistance Fund Program (HAF), Coronavirus State and Local Fiscal Recovery Funds (SLFRF), Twenty-First Century Community Learning Centers (Twenty-First), Title I Grants to Local Education Agencies (Title I), Supporting Effective Instruction State Grants (SEISG), Education Stabilization Funds (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families Cluster (TANF), Child Support Enforcement (CSE), Low-Income Home Energy Assistance Program (LIHEAP), Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant (SSBG), and Block Grants for Prevention and Treatment of Substance Abuse (SAPT) in the State's Grant Accountability and Transparency Act (GATA) Audit Report Review Management System (ARRMS). The State of Illinois established the Grant Accountability Transparency Unit (GATU) to implement the provisions of GATA on a centralized basis. GATU has established standardized reporting requirements for subrecipients of the various Federal programs administered by the State through its various departments. Subrecipients of the State are required to certify whether they expended more than $750,000 in federal awards during the fiscal year and submit their single audit reporting packages to the Federal Audit Clearinghouse (if required). GATU is then responsible for obtaining the single audit reporting package, verifying the report meets the single audit requirements, and assigning, to the applicable state agency, any findings attributable to amounts passed through to the subrecipient(s) by the State and working with program personnel to issue management decisions on findings. The State utilizes a contractor to perform the centralized functions of obtaining the single audit report, verifying the report meets the requirements, and assigning findings to the applicable State agency. During our testing of subrecipient single audit desk review files for our 2023 major programs, we noted instances where single audit desk reviews were still in process and had not been finalized within GATA ARRMS as of the date of our testing (October 7, 2024). One subrecipient in our sample for the WIC program had incomplete single audit reviews for fiscal years 2019 through 2022, despite the fact the State had obtained the single audit report from the Federal Audit Clearinghouse for each of these fiscal years. Upon further review of data contained within GATA ARRMS, we identified 669 single audit reviews were identified as incomplete in GATA ARRMS for grantees who: (1) reported expenditures under fiscal year 2023 major programs, (2) had an audit report with a FAC acceptance date between January 2, 2022 and January 3, 2023 (requiring the report to be reviewed during fiscal year 2023) and (3) were not sanctioned (placed on the Illinois Stop Payment List) by the State for noncompliance with reporting requirements. These 669 reviews were in varying stages of completion with the majority (608 audits) pending documentation supporting the issuance of a final completion letter by the cognizant agency. The remaining 61 audits (9.1%) were pending receipt of documentation, pending a review, or had another error requiring follow-up. These 669 audits included 323 audits (48.3%) with one or more findings potentially requiring a management decision to be issued. We noted the cognizant agencies for the 669 incomplete single audit reviews in GATA ARRMS were as follows: "See Table in the Audit Report". The 669 incomplete single audit reviews in GATA ARRMS pertained to subrecipients of the following major programs: "See Table in the Audit Report". While in many instances there was evidence the State agencies had completed the necessary procedures outside of GATA ARRMS, the purpose of GATA ARRMS is to reduce the duplication of effort across State agencies and to provide a single submission point for the State’s subrecipients. The lack of monitoring controls around this centralized process may result in noncompliance with subrecipient single audit desk review requirements. The State’s subrecipient expenditures under the federal programs for the year ended June 30, 2023 were as follows: "See Table in the Audit Report". Criteria or Requirement: According to 2 CFR 200.332(d), a pass-through entity is required to monitor the activities of subrecipients as necessary to ensure the federal awards are used for authorized purposes in compliance with laws, regulations, and the provisions of contracts or grant agreements and that performance goals are achieved. Further, 2 CFR 200.332(d)(3) and 2 CFR 200.521 state that a pass-through entity is required to issue a management decision on audit findings within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC) and ensure that the subrecipient takes timely and appropriate corrective action on all audit findings. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, 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. Effective internal controls should include implementing procedures to monitor whether single audit reports are reviewed, management decision letters are issued, and single audit desk review files are closed out in GATA ARRMS in a timely manner. Cause: In discussing these conditions with GOMB officials, management stated that the incompleteness of the State’s audit reviews in GATA ARRMS was due to oversight. Possible Asserted Effect: Failure to complete and document reviews of subrecipient single audit reports in GATA ARRMS in a timely manner may result in noncompliance with the State’s obligation as a pass-through entity to appropriately monitor its subrecipients. Repeat Finding: A similar finding was not reported in the prior year audit (Finding Code 2023-002). Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend GOMB establish procedures to monitor the completion and documentation of single audit report reviews in GATA ARRMS to ensure the State complies with its obligation as a pass-through entity. Views of GOMB Officials: GOMB agrees with the finding.
State Agency: Illinois Governor’s Office of Management and Budget (GOMB) Federal Agency: U.S. Department of Agriculture (USDA), U.S. Department of Justice (DOJ), U.S. Department of Labor (DOL), U.S. Department of Transportation (DOT), U.S. Department of the Treasury (TREAS), U.S. Department of Education (ED), U.S. Department of Health and Human Services (USDHHS) Program Name: Special Supplemental Nutrition Program for Women, Infants and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program, WIOA Cluster, Highway Planning and Construction, Emergency Rental Assistance Program, Homeowner Assistance Fund Program, Coronavirus State and Local Fiscal Recovery Funds, Title I Grants to Local Educational Agencies, Twenty-First Century Community Learning Centers, Supporting Effective Instruction State Grants, Education Stabilization Fund (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families (TANF), Child Support Enforcement, Low-Income Home Energy Assistance Program, Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant, Block Grants for Prevention and Treatment of Substance Abuse ALN and Program Expenditures 10.557 ($168,740,425), 10.558 ($156,353,139), 16.575 ($78,196,419), 17.258/17.259/17.278 ($141,177,677), 20.205 ($1,932,300,419), 21.023 ($179,355,381), 21.026 ($177,107,928), 21.027 ($2,804,581,453), 84.010A ($704,235,726), 84.287 ($77,436,583),84.367A ($76,537,613), 84.425 ($2,227,152,891), 93.323 ($174,636,052), 93.558 ($578,867,422), 93.563 ($131,300,355), 93.568 ($288,503,657), 93.575/93.596 ($783,907,069), 93.667 ($57,147,970), 93.959 ($101,011,200) Award Numbers: Various – see table of award numbers Federal Award Year: Various – see table of award numbers Questioned Costs: None Finding 2023-002: Inadequate Monitoring of Subrecipient Single Audit Reviews Compliance Requirement: Subrecipient Monitoring Condition Found: The State of Illinois did not establish adequate controls to monitor the completion and documentation of the review single audit reports for its subrecipients of the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program (CVA), WIOA Cluster (WIOA), Highway and Planning Construction (Highway), Emergency Rental Assistance Program (ERAP), Homeowner Assistance Fund Program (HAF), Coronavirus State and Local Fiscal Recovery Funds (SLFRF), Twenty-First Century Community Learning Centers (Twenty-First), Title I Grants to Local Education Agencies (Title I), Supporting Effective Instruction State Grants (SEISG), Education Stabilization Funds (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families Cluster (TANF), Child Support Enforcement (CSE), Low-Income Home Energy Assistance Program (LIHEAP), Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant (SSBG), and Block Grants for Prevention and Treatment of Substance Abuse (SAPT) in the State's Grant Accountability and Transparency Act (GATA) Audit Report Review Management System (ARRMS). The State of Illinois established the Grant Accountability Transparency Unit (GATU) to implement the provisions of GATA on a centralized basis. GATU has established standardized reporting requirements for subrecipients of the various Federal programs administered by the State through its various departments. Subrecipients of the State are required to certify whether they expended more than $750,000 in federal awards during the fiscal year and submit their single audit reporting packages to the Federal Audit Clearinghouse (if required). GATU is then responsible for obtaining the single audit reporting package, verifying the report meets the single audit requirements, and assigning, to the applicable state agency, any findings attributable to amounts passed through to the subrecipient(s) by the State and working with program personnel to issue management decisions on findings. The State utilizes a contractor to perform the centralized functions of obtaining the single audit report, verifying the report meets the requirements, and assigning findings to the applicable State agency. During our testing of subrecipient single audit desk review files for our 2023 major programs, we noted instances where single audit desk reviews were still in process and had not been finalized within GATA ARRMS as of the date of our testing (October 7, 2024). One subrecipient in our sample for the WIC program had incomplete single audit reviews for fiscal years 2019 through 2022, despite the fact the State had obtained the single audit report from the Federal Audit Clearinghouse for each of these fiscal years. Upon further review of data contained within GATA ARRMS, we identified 669 single audit reviews were identified as incomplete in GATA ARRMS for grantees who: (1) reported expenditures under fiscal year 2023 major programs, (2) had an audit report with a FAC acceptance date between January 2, 2022 and January 3, 2023 (requiring the report to be reviewed during fiscal year 2023) and (3) were not sanctioned (placed on the Illinois Stop Payment List) by the State for noncompliance with reporting requirements. These 669 reviews were in varying stages of completion with the majority (608 audits) pending documentation supporting the issuance of a final completion letter by the cognizant agency. The remaining 61 audits (9.1%) were pending receipt of documentation, pending a review, or had another error requiring follow-up. These 669 audits included 323 audits (48.3%) with one or more findings potentially requiring a management decision to be issued. We noted the cognizant agencies for the 669 incomplete single audit reviews in GATA ARRMS were as follows: "See Table in the Audit Report". The 669 incomplete single audit reviews in GATA ARRMS pertained to subrecipients of the following major programs: "See Table in the Audit Report". While in many instances there was evidence the State agencies had completed the necessary procedures outside of GATA ARRMS, the purpose of GATA ARRMS is to reduce the duplication of effort across State agencies and to provide a single submission point for the State’s subrecipients. The lack of monitoring controls around this centralized process may result in noncompliance with subrecipient single audit desk review requirements. The State’s subrecipient expenditures under the federal programs for the year ended June 30, 2023 were as follows: "See Table in the Audit Report". Criteria or Requirement: According to 2 CFR 200.332(d), a pass-through entity is required to monitor the activities of subrecipients as necessary to ensure the federal awards are used for authorized purposes in compliance with laws, regulations, and the provisions of contracts or grant agreements and that performance goals are achieved. Further, 2 CFR 200.332(d)(3) and 2 CFR 200.521 state that a pass-through entity is required to issue a management decision on audit findings within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC) and ensure that the subrecipient takes timely and appropriate corrective action on all audit findings. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, 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. Effective internal controls should include implementing procedures to monitor whether single audit reports are reviewed, management decision letters are issued, and single audit desk review files are closed out in GATA ARRMS in a timely manner. Cause: In discussing these conditions with GOMB officials, management stated that the incompleteness of the State’s audit reviews in GATA ARRMS was due to oversight. Possible Asserted Effect: Failure to complete and document reviews of subrecipient single audit reports in GATA ARRMS in a timely manner may result in noncompliance with the State’s obligation as a pass-through entity to appropriately monitor its subrecipients. Repeat Finding: A similar finding was not reported in the prior year audit (Finding Code 2023-002). Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend GOMB establish procedures to monitor the completion and documentation of single audit report reviews in GATA ARRMS to ensure the State complies with its obligation as a pass-through entity. Views of GOMB Officials: GOMB agrees with the finding.
State Agency: Illinois Governor’s Office of Management and Budget (GOMB) Federal Agency: U.S. Department of Agriculture (USDA), U.S. Department of Justice (DOJ), U.S. Department of Labor (DOL), U.S. Department of Transportation (DOT), U.S. Department of the Treasury (TREAS), U.S. Department of Education (ED), U.S. Department of Health and Human Services (USDHHS) Program Name: Special Supplemental Nutrition Program for Women, Infants and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program, WIOA Cluster, Highway Planning and Construction, Emergency Rental Assistance Program, Homeowner Assistance Fund Program, Coronavirus State and Local Fiscal Recovery Funds, Title I Grants to Local Educational Agencies, Twenty-First Century Community Learning Centers, Supporting Effective Instruction State Grants, Education Stabilization Fund (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families (TANF), Child Support Enforcement, Low-Income Home Energy Assistance Program, Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant, Block Grants for Prevention and Treatment of Substance Abuse ALN and Program Expenditures 10.557 ($168,740,425), 10.558 ($156,353,139), 16.575 ($78,196,419), 17.258/17.259/17.278 ($141,177,677), 20.205 ($1,932,300,419), 21.023 ($179,355,381), 21.026 ($177,107,928), 21.027 ($2,804,581,453), 84.010A ($704,235,726), 84.287 ($77,436,583),84.367A ($76,537,613), 84.425 ($2,227,152,891), 93.323 ($174,636,052), 93.558 ($578,867,422), 93.563 ($131,300,355), 93.568 ($288,503,657), 93.575/93.596 ($783,907,069), 93.667 ($57,147,970), 93.959 ($101,011,200) Award Numbers: Various – see table of award numbers Federal Award Year: Various – see table of award numbers Questioned Costs: None Finding 2023-002: Inadequate Monitoring of Subrecipient Single Audit Reviews Compliance Requirement: Subrecipient Monitoring Condition Found: The State of Illinois did not establish adequate controls to monitor the completion and documentation of the review single audit reports for its subrecipients of the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program (CVA), WIOA Cluster (WIOA), Highway and Planning Construction (Highway), Emergency Rental Assistance Program (ERAP), Homeowner Assistance Fund Program (HAF), Coronavirus State and Local Fiscal Recovery Funds (SLFRF), Twenty-First Century Community Learning Centers (Twenty-First), Title I Grants to Local Education Agencies (Title I), Supporting Effective Instruction State Grants (SEISG), Education Stabilization Funds (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families Cluster (TANF), Child Support Enforcement (CSE), Low-Income Home Energy Assistance Program (LIHEAP), Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant (SSBG), and Block Grants for Prevention and Treatment of Substance Abuse (SAPT) in the State's Grant Accountability and Transparency Act (GATA) Audit Report Review Management System (ARRMS). The State of Illinois established the Grant Accountability Transparency Unit (GATU) to implement the provisions of GATA on a centralized basis. GATU has established standardized reporting requirements for subrecipients of the various Federal programs administered by the State through its various departments. Subrecipients of the State are required to certify whether they expended more than $750,000 in federal awards during the fiscal year and submit their single audit reporting packages to the Federal Audit Clearinghouse (if required). GATU is then responsible for obtaining the single audit reporting package, verifying the report meets the single audit requirements, and assigning, to the applicable state agency, any findings attributable to amounts passed through to the subrecipient(s) by the State and working with program personnel to issue management decisions on findings. The State utilizes a contractor to perform the centralized functions of obtaining the single audit report, verifying the report meets the requirements, and assigning findings to the applicable State agency. During our testing of subrecipient single audit desk review files for our 2023 major programs, we noted instances where single audit desk reviews were still in process and had not been finalized within GATA ARRMS as of the date of our testing (October 7, 2024). One subrecipient in our sample for the WIC program had incomplete single audit reviews for fiscal years 2019 through 2022, despite the fact the State had obtained the single audit report from the Federal Audit Clearinghouse for each of these fiscal years. Upon further review of data contained within GATA ARRMS, we identified 669 single audit reviews were identified as incomplete in GATA ARRMS for grantees who: (1) reported expenditures under fiscal year 2023 major programs, (2) had an audit report with a FAC acceptance date between January 2, 2022 and January 3, 2023 (requiring the report to be reviewed during fiscal year 2023) and (3) were not sanctioned (placed on the Illinois Stop Payment List) by the State for noncompliance with reporting requirements. These 669 reviews were in varying stages of completion with the majority (608 audits) pending documentation supporting the issuance of a final completion letter by the cognizant agency. The remaining 61 audits (9.1%) were pending receipt of documentation, pending a review, or had another error requiring follow-up. These 669 audits included 323 audits (48.3%) with one or more findings potentially requiring a management decision to be issued. We noted the cognizant agencies for the 669 incomplete single audit reviews in GATA ARRMS were as follows: "See Table in the Audit Report". The 669 incomplete single audit reviews in GATA ARRMS pertained to subrecipients of the following major programs: "See Table in the Audit Report". While in many instances there was evidence the State agencies had completed the necessary procedures outside of GATA ARRMS, the purpose of GATA ARRMS is to reduce the duplication of effort across State agencies and to provide a single submission point for the State’s subrecipients. The lack of monitoring controls around this centralized process may result in noncompliance with subrecipient single audit desk review requirements. The State’s subrecipient expenditures under the federal programs for the year ended June 30, 2023 were as follows: "See Table in the Audit Report". Criteria or Requirement: According to 2 CFR 200.332(d), a pass-through entity is required to monitor the activities of subrecipients as necessary to ensure the federal awards are used for authorized purposes in compliance with laws, regulations, and the provisions of contracts or grant agreements and that performance goals are achieved. Further, 2 CFR 200.332(d)(3) and 2 CFR 200.521 state that a pass-through entity is required to issue a management decision on audit findings within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC) and ensure that the subrecipient takes timely and appropriate corrective action on all audit findings. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, 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. Effective internal controls should include implementing procedures to monitor whether single audit reports are reviewed, management decision letters are issued, and single audit desk review files are closed out in GATA ARRMS in a timely manner. Cause: In discussing these conditions with GOMB officials, management stated that the incompleteness of the State’s audit reviews in GATA ARRMS was due to oversight. Possible Asserted Effect: Failure to complete and document reviews of subrecipient single audit reports in GATA ARRMS in a timely manner may result in noncompliance with the State’s obligation as a pass-through entity to appropriately monitor its subrecipients. Repeat Finding: A similar finding was not reported in the prior year audit (Finding Code 2023-002). Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend GOMB establish procedures to monitor the completion and documentation of single audit report reviews in GATA ARRMS to ensure the State complies with its obligation as a pass-through entity. Views of GOMB Officials: GOMB agrees with the finding.
State Agency: Illinois Governor’s Office of Management and Budget (GOMB) Federal Agency: U.S. Department of Agriculture (USDA), U.S. Department of Justice (DOJ), U.S. Department of Labor (DOL), U.S. Department of Transportation (DOT), U.S. Department of the Treasury (TREAS), U.S. Department of Education (ED), U.S. Department of Health and Human Services (USDHHS) Program Name: Special Supplemental Nutrition Program for Women, Infants and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program, WIOA Cluster, Highway Planning and Construction, Emergency Rental Assistance Program, Homeowner Assistance Fund Program, Coronavirus State and Local Fiscal Recovery Funds, Title I Grants to Local Educational Agencies, Twenty-First Century Community Learning Centers, Supporting Effective Instruction State Grants, Education Stabilization Fund (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families (TANF), Child Support Enforcement, Low-Income Home Energy Assistance Program, Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant, Block Grants for Prevention and Treatment of Substance Abuse ALN and Program Expenditures 10.557 ($168,740,425), 10.558 ($156,353,139), 16.575 ($78,196,419), 17.258/17.259/17.278 ($141,177,677), 20.205 ($1,932,300,419), 21.023 ($179,355,381), 21.026 ($177,107,928), 21.027 ($2,804,581,453), 84.010A ($704,235,726), 84.287 ($77,436,583),84.367A ($76,537,613), 84.425 ($2,227,152,891), 93.323 ($174,636,052), 93.558 ($578,867,422), 93.563 ($131,300,355), 93.568 ($288,503,657), 93.575/93.596 ($783,907,069), 93.667 ($57,147,970), 93.959 ($101,011,200) Award Numbers: Various – see table of award numbers Federal Award Year: Various – see table of award numbers Questioned Costs: None Finding 2023-002: Inadequate Monitoring of Subrecipient Single Audit Reviews Compliance Requirement: Subrecipient Monitoring Condition Found: The State of Illinois did not establish adequate controls to monitor the completion and documentation of the review single audit reports for its subrecipients of the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program (CVA), WIOA Cluster (WIOA), Highway and Planning Construction (Highway), Emergency Rental Assistance Program (ERAP), Homeowner Assistance Fund Program (HAF), Coronavirus State and Local Fiscal Recovery Funds (SLFRF), Twenty-First Century Community Learning Centers (Twenty-First), Title I Grants to Local Education Agencies (Title I), Supporting Effective Instruction State Grants (SEISG), Education Stabilization Funds (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families Cluster (TANF), Child Support Enforcement (CSE), Low-Income Home Energy Assistance Program (LIHEAP), Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant (SSBG), and Block Grants for Prevention and Treatment of Substance Abuse (SAPT) in the State's Grant Accountability and Transparency Act (GATA) Audit Report Review Management System (ARRMS). The State of Illinois established the Grant Accountability Transparency Unit (GATU) to implement the provisions of GATA on a centralized basis. GATU has established standardized reporting requirements for subrecipients of the various Federal programs administered by the State through its various departments. Subrecipients of the State are required to certify whether they expended more than $750,000 in federal awards during the fiscal year and submit their single audit reporting packages to the Federal Audit Clearinghouse (if required). GATU is then responsible for obtaining the single audit reporting package, verifying the report meets the single audit requirements, and assigning, to the applicable state agency, any findings attributable to amounts passed through to the subrecipient(s) by the State and working with program personnel to issue management decisions on findings. The State utilizes a contractor to perform the centralized functions of obtaining the single audit report, verifying the report meets the requirements, and assigning findings to the applicable State agency. During our testing of subrecipient single audit desk review files for our 2023 major programs, we noted instances where single audit desk reviews were still in process and had not been finalized within GATA ARRMS as of the date of our testing (October 7, 2024). One subrecipient in our sample for the WIC program had incomplete single audit reviews for fiscal years 2019 through 2022, despite the fact the State had obtained the single audit report from the Federal Audit Clearinghouse for each of these fiscal years. Upon further review of data contained within GATA ARRMS, we identified 669 single audit reviews were identified as incomplete in GATA ARRMS for grantees who: (1) reported expenditures under fiscal year 2023 major programs, (2) had an audit report with a FAC acceptance date between January 2, 2022 and January 3, 2023 (requiring the report to be reviewed during fiscal year 2023) and (3) were not sanctioned (placed on the Illinois Stop Payment List) by the State for noncompliance with reporting requirements. These 669 reviews were in varying stages of completion with the majority (608 audits) pending documentation supporting the issuance of a final completion letter by the cognizant agency. The remaining 61 audits (9.1%) were pending receipt of documentation, pending a review, or had another error requiring follow-up. These 669 audits included 323 audits (48.3%) with one or more findings potentially requiring a management decision to be issued. We noted the cognizant agencies for the 669 incomplete single audit reviews in GATA ARRMS were as follows: "See Table in the Audit Report". The 669 incomplete single audit reviews in GATA ARRMS pertained to subrecipients of the following major programs: "See Table in the Audit Report". While in many instances there was evidence the State agencies had completed the necessary procedures outside of GATA ARRMS, the purpose of GATA ARRMS is to reduce the duplication of effort across State agencies and to provide a single submission point for the State’s subrecipients. The lack of monitoring controls around this centralized process may result in noncompliance with subrecipient single audit desk review requirements. The State’s subrecipient expenditures under the federal programs for the year ended June 30, 2023 were as follows: "See Table in the Audit Report". Criteria or Requirement: According to 2 CFR 200.332(d), a pass-through entity is required to monitor the activities of subrecipients as necessary to ensure the federal awards are used for authorized purposes in compliance with laws, regulations, and the provisions of contracts or grant agreements and that performance goals are achieved. Further, 2 CFR 200.332(d)(3) and 2 CFR 200.521 state that a pass-through entity is required to issue a management decision on audit findings within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC) and ensure that the subrecipient takes timely and appropriate corrective action on all audit findings. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, 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. Effective internal controls should include implementing procedures to monitor whether single audit reports are reviewed, management decision letters are issued, and single audit desk review files are closed out in GATA ARRMS in a timely manner. Cause: In discussing these conditions with GOMB officials, management stated that the incompleteness of the State’s audit reviews in GATA ARRMS was due to oversight. Possible Asserted Effect: Failure to complete and document reviews of subrecipient single audit reports in GATA ARRMS in a timely manner may result in noncompliance with the State’s obligation as a pass-through entity to appropriately monitor its subrecipients. Repeat Finding: A similar finding was not reported in the prior year audit (Finding Code 2023-002). Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend GOMB establish procedures to monitor the completion and documentation of single audit report reviews in GATA ARRMS to ensure the State complies with its obligation as a pass-through entity. Views of GOMB Officials: GOMB agrees with the finding.
State Agency: Illinois Governor’s Office of Management and Budget (GOMB) Federal Agency: U.S. Department of Agriculture (USDA), U.S. Department of Justice (DOJ), U.S. Department of Labor (DOL), U.S. Department of Transportation (DOT), U.S. Department of the Treasury (TREAS), U.S. Department of Education (ED), U.S. Department of Health and Human Services (USDHHS) Program Name: Special Supplemental Nutrition Program for Women, Infants and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program, WIOA Cluster, Highway Planning and Construction, Emergency Rental Assistance Program, Homeowner Assistance Fund Program, Coronavirus State and Local Fiscal Recovery Funds, Title I Grants to Local Educational Agencies, Twenty-First Century Community Learning Centers, Supporting Effective Instruction State Grants, Education Stabilization Fund (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families (TANF), Child Support Enforcement, Low-Income Home Energy Assistance Program, Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant, Block Grants for Prevention and Treatment of Substance Abuse ALN and Program Expenditures 10.557 ($168,740,425), 10.558 ($156,353,139), 16.575 ($78,196,419), 17.258/17.259/17.278 ($141,177,677), 20.205 ($1,932,300,419), 21.023 ($179,355,381), 21.026 ($177,107,928), 21.027 ($2,804,581,453), 84.010A ($704,235,726), 84.287 ($77,436,583),84.367A ($76,537,613), 84.425 ($2,227,152,891), 93.323 ($174,636,052), 93.558 ($578,867,422), 93.563 ($131,300,355), 93.568 ($288,503,657), 93.575/93.596 ($783,907,069), 93.667 ($57,147,970), 93.959 ($101,011,200) Award Numbers: Various – see table of award numbers Federal Award Year: Various – see table of award numbers Questioned Costs: None Finding 2023-002: Inadequate Monitoring of Subrecipient Single Audit Reviews Compliance Requirement: Subrecipient Monitoring Condition Found: The State of Illinois did not establish adequate controls to monitor the completion and documentation of the review single audit reports for its subrecipients of the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program (CVA), WIOA Cluster (WIOA), Highway and Planning Construction (Highway), Emergency Rental Assistance Program (ERAP), Homeowner Assistance Fund Program (HAF), Coronavirus State and Local Fiscal Recovery Funds (SLFRF), Twenty-First Century Community Learning Centers (Twenty-First), Title I Grants to Local Education Agencies (Title I), Supporting Effective Instruction State Grants (SEISG), Education Stabilization Funds (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families Cluster (TANF), Child Support Enforcement (CSE), Low-Income Home Energy Assistance Program (LIHEAP), Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant (SSBG), and Block Grants for Prevention and Treatment of Substance Abuse (SAPT) in the State's Grant Accountability and Transparency Act (GATA) Audit Report Review Management System (ARRMS). The State of Illinois established the Grant Accountability Transparency Unit (GATU) to implement the provisions of GATA on a centralized basis. GATU has established standardized reporting requirements for subrecipients of the various Federal programs administered by the State through its various departments. Subrecipients of the State are required to certify whether they expended more than $750,000 in federal awards during the fiscal year and submit their single audit reporting packages to the Federal Audit Clearinghouse (if required). GATU is then responsible for obtaining the single audit reporting package, verifying the report meets the single audit requirements, and assigning, to the applicable state agency, any findings attributable to amounts passed through to the subrecipient(s) by the State and working with program personnel to issue management decisions on findings. The State utilizes a contractor to perform the centralized functions of obtaining the single audit report, verifying the report meets the requirements, and assigning findings to the applicable State agency. During our testing of subrecipient single audit desk review files for our 2023 major programs, we noted instances where single audit desk reviews were still in process and had not been finalized within GATA ARRMS as of the date of our testing (October 7, 2024). One subrecipient in our sample for the WIC program had incomplete single audit reviews for fiscal years 2019 through 2022, despite the fact the State had obtained the single audit report from the Federal Audit Clearinghouse for each of these fiscal years. Upon further review of data contained within GATA ARRMS, we identified 669 single audit reviews were identified as incomplete in GATA ARRMS for grantees who: (1) reported expenditures under fiscal year 2023 major programs, (2) had an audit report with a FAC acceptance date between January 2, 2022 and January 3, 2023 (requiring the report to be reviewed during fiscal year 2023) and (3) were not sanctioned (placed on the Illinois Stop Payment List) by the State for noncompliance with reporting requirements. These 669 reviews were in varying stages of completion with the majority (608 audits) pending documentation supporting the issuance of a final completion letter by the cognizant agency. The remaining 61 audits (9.1%) were pending receipt of documentation, pending a review, or had another error requiring follow-up. These 669 audits included 323 audits (48.3%) with one or more findings potentially requiring a management decision to be issued. We noted the cognizant agencies for the 669 incomplete single audit reviews in GATA ARRMS were as follows: "See Table in the Audit Report". The 669 incomplete single audit reviews in GATA ARRMS pertained to subrecipients of the following major programs: "See Table in the Audit Report". While in many instances there was evidence the State agencies had completed the necessary procedures outside of GATA ARRMS, the purpose of GATA ARRMS is to reduce the duplication of effort across State agencies and to provide a single submission point for the State’s subrecipients. The lack of monitoring controls around this centralized process may result in noncompliance with subrecipient single audit desk review requirements. The State’s subrecipient expenditures under the federal programs for the year ended June 30, 2023 were as follows: "See Table in the Audit Report". Criteria or Requirement: According to 2 CFR 200.332(d), a pass-through entity is required to monitor the activities of subrecipients as necessary to ensure the federal awards are used for authorized purposes in compliance with laws, regulations, and the provisions of contracts or grant agreements and that performance goals are achieved. Further, 2 CFR 200.332(d)(3) and 2 CFR 200.521 state that a pass-through entity is required to issue a management decision on audit findings within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC) and ensure that the subrecipient takes timely and appropriate corrective action on all audit findings. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, 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. Effective internal controls should include implementing procedures to monitor whether single audit reports are reviewed, management decision letters are issued, and single audit desk review files are closed out in GATA ARRMS in a timely manner. Cause: In discussing these conditions with GOMB officials, management stated that the incompleteness of the State’s audit reviews in GATA ARRMS was due to oversight. Possible Asserted Effect: Failure to complete and document reviews of subrecipient single audit reports in GATA ARRMS in a timely manner may result in noncompliance with the State’s obligation as a pass-through entity to appropriately monitor its subrecipients. Repeat Finding: A similar finding was not reported in the prior year audit (Finding Code 2023-002). Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend GOMB establish procedures to monitor the completion and documentation of single audit report reviews in GATA ARRMS to ensure the State complies with its obligation as a pass-through entity. Views of GOMB Officials: GOMB agrees with the finding.
State Agency: Illinois Governor’s Office of Management and Budget (GOMB) Federal Agency: U.S. Department of Agriculture (USDA), U.S. Department of Justice (DOJ), U.S. Department of Labor (DOL), U.S. Department of Transportation (DOT), U.S. Department of the Treasury (TREAS), U.S. Department of Education (ED), U.S. Department of Health and Human Services (USDHHS) Program Name: Special Supplemental Nutrition Program for Women, Infants and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program, WIOA Cluster, Highway Planning and Construction, Emergency Rental Assistance Program, Homeowner Assistance Fund Program, Coronavirus State and Local Fiscal Recovery Funds, Title I Grants to Local Educational Agencies, Twenty-First Century Community Learning Centers, Supporting Effective Instruction State Grants, Education Stabilization Fund (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families (TANF), Child Support Enforcement, Low-Income Home Energy Assistance Program, Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant, Block Grants for Prevention and Treatment of Substance Abuse ALN and Program Expenditures 10.557 ($168,740,425), 10.558 ($156,353,139), 16.575 ($78,196,419), 17.258/17.259/17.278 ($141,177,677), 20.205 ($1,932,300,419), 21.023 ($179,355,381), 21.026 ($177,107,928), 21.027 ($2,804,581,453), 84.010A ($704,235,726), 84.287 ($77,436,583),84.367A ($76,537,613), 84.425 ($2,227,152,891), 93.323 ($174,636,052), 93.558 ($578,867,422), 93.563 ($131,300,355), 93.568 ($288,503,657), 93.575/93.596 ($783,907,069), 93.667 ($57,147,970), 93.959 ($101,011,200) Award Numbers: Various – see table of award numbers Federal Award Year: Various – see table of award numbers Questioned Costs: None Finding 2023-002: Inadequate Monitoring of Subrecipient Single Audit Reviews Compliance Requirement: Subrecipient Monitoring Condition Found: The State of Illinois did not establish adequate controls to monitor the completion and documentation of the review single audit reports for its subrecipients of the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program (CVA), WIOA Cluster (WIOA), Highway and Planning Construction (Highway), Emergency Rental Assistance Program (ERAP), Homeowner Assistance Fund Program (HAF), Coronavirus State and Local Fiscal Recovery Funds (SLFRF), Twenty-First Century Community Learning Centers (Twenty-First), Title I Grants to Local Education Agencies (Title I), Supporting Effective Instruction State Grants (SEISG), Education Stabilization Funds (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families Cluster (TANF), Child Support Enforcement (CSE), Low-Income Home Energy Assistance Program (LIHEAP), Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant (SSBG), and Block Grants for Prevention and Treatment of Substance Abuse (SAPT) in the State's Grant Accountability and Transparency Act (GATA) Audit Report Review Management System (ARRMS). The State of Illinois established the Grant Accountability Transparency Unit (GATU) to implement the provisions of GATA on a centralized basis. GATU has established standardized reporting requirements for subrecipients of the various Federal programs administered by the State through its various departments. Subrecipients of the State are required to certify whether they expended more than $750,000 in federal awards during the fiscal year and submit their single audit reporting packages to the Federal Audit Clearinghouse (if required). GATU is then responsible for obtaining the single audit reporting package, verifying the report meets the single audit requirements, and assigning, to the applicable state agency, any findings attributable to amounts passed through to the subrecipient(s) by the State and working with program personnel to issue management decisions on findings. The State utilizes a contractor to perform the centralized functions of obtaining the single audit report, verifying the report meets the requirements, and assigning findings to the applicable State agency. During our testing of subrecipient single audit desk review files for our 2023 major programs, we noted instances where single audit desk reviews were still in process and had not been finalized within GATA ARRMS as of the date of our testing (October 7, 2024). One subrecipient in our sample for the WIC program had incomplete single audit reviews for fiscal years 2019 through 2022, despite the fact the State had obtained the single audit report from the Federal Audit Clearinghouse for each of these fiscal years. Upon further review of data contained within GATA ARRMS, we identified 669 single audit reviews were identified as incomplete in GATA ARRMS for grantees who: (1) reported expenditures under fiscal year 2023 major programs, (2) had an audit report with a FAC acceptance date between January 2, 2022 and January 3, 2023 (requiring the report to be reviewed during fiscal year 2023) and (3) were not sanctioned (placed on the Illinois Stop Payment List) by the State for noncompliance with reporting requirements. These 669 reviews were in varying stages of completion with the majority (608 audits) pending documentation supporting the issuance of a final completion letter by the cognizant agency. The remaining 61 audits (9.1%) were pending receipt of documentation, pending a review, or had another error requiring follow-up. These 669 audits included 323 audits (48.3%) with one or more findings potentially requiring a management decision to be issued. We noted the cognizant agencies for the 669 incomplete single audit reviews in GATA ARRMS were as follows: "See Table in the Audit Report". The 669 incomplete single audit reviews in GATA ARRMS pertained to subrecipients of the following major programs: "See Table in the Audit Report". While in many instances there was evidence the State agencies had completed the necessary procedures outside of GATA ARRMS, the purpose of GATA ARRMS is to reduce the duplication of effort across State agencies and to provide a single submission point for the State’s subrecipients. The lack of monitoring controls around this centralized process may result in noncompliance with subrecipient single audit desk review requirements. The State’s subrecipient expenditures under the federal programs for the year ended June 30, 2023 were as follows: "See Table in the Audit Report". Criteria or Requirement: According to 2 CFR 200.332(d), a pass-through entity is required to monitor the activities of subrecipients as necessary to ensure the federal awards are used for authorized purposes in compliance with laws, regulations, and the provisions of contracts or grant agreements and that performance goals are achieved. Further, 2 CFR 200.332(d)(3) and 2 CFR 200.521 state that a pass-through entity is required to issue a management decision on audit findings within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC) and ensure that the subrecipient takes timely and appropriate corrective action on all audit findings. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, 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. Effective internal controls should include implementing procedures to monitor whether single audit reports are reviewed, management decision letters are issued, and single audit desk review files are closed out in GATA ARRMS in a timely manner. Cause: In discussing these conditions with GOMB officials, management stated that the incompleteness of the State’s audit reviews in GATA ARRMS was due to oversight. Possible Asserted Effect: Failure to complete and document reviews of subrecipient single audit reports in GATA ARRMS in a timely manner may result in noncompliance with the State’s obligation as a pass-through entity to appropriately monitor its subrecipients. Repeat Finding: A similar finding was not reported in the prior year audit (Finding Code 2023-002). Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend GOMB establish procedures to monitor the completion and documentation of single audit report reviews in GATA ARRMS to ensure the State complies with its obligation as a pass-through entity. Views of GOMB Officials: GOMB agrees with the finding.
State Agency: Illinois Governor’s Office of Management and Budget (GOMB) Federal Agency: U.S. Department of Agriculture (USDA), U.S. Department of Justice (DOJ), U.S. Department of Labor (DOL), U.S. Department of Transportation (DOT), U.S. Department of the Treasury (TREAS), U.S. Department of Education (ED), U.S. Department of Health and Human Services (USDHHS) Program Name: Special Supplemental Nutrition Program for Women, Infants and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program, WIOA Cluster, Highway Planning and Construction, Emergency Rental Assistance Program, Homeowner Assistance Fund Program, Coronavirus State and Local Fiscal Recovery Funds, Title I Grants to Local Educational Agencies, Twenty-First Century Community Learning Centers, Supporting Effective Instruction State Grants, Education Stabilization Fund (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families (TANF), Child Support Enforcement, Low-Income Home Energy Assistance Program, Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant, Block Grants for Prevention and Treatment of Substance Abuse ALN and Program Expenditures 10.557 ($168,740,425), 10.558 ($156,353,139), 16.575 ($78,196,419), 17.258/17.259/17.278 ($141,177,677), 20.205 ($1,932,300,419), 21.023 ($179,355,381), 21.026 ($177,107,928), 21.027 ($2,804,581,453), 84.010A ($704,235,726), 84.287 ($77,436,583),84.367A ($76,537,613), 84.425 ($2,227,152,891), 93.323 ($174,636,052), 93.558 ($578,867,422), 93.563 ($131,300,355), 93.568 ($288,503,657), 93.575/93.596 ($783,907,069), 93.667 ($57,147,970), 93.959 ($101,011,200) Award Numbers: Various – see table of award numbers Federal Award Year: Various – see table of award numbers Questioned Costs: None Finding 2023-002: Inadequate Monitoring of Subrecipient Single Audit Reviews Compliance Requirement: Subrecipient Monitoring Condition Found: The State of Illinois did not establish adequate controls to monitor the completion and documentation of the review single audit reports for its subrecipients of the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program (CVA), WIOA Cluster (WIOA), Highway and Planning Construction (Highway), Emergency Rental Assistance Program (ERAP), Homeowner Assistance Fund Program (HAF), Coronavirus State and Local Fiscal Recovery Funds (SLFRF), Twenty-First Century Community Learning Centers (Twenty-First), Title I Grants to Local Education Agencies (Title I), Supporting Effective Instruction State Grants (SEISG), Education Stabilization Funds (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families Cluster (TANF), Child Support Enforcement (CSE), Low-Income Home Energy Assistance Program (LIHEAP), Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant (SSBG), and Block Grants for Prevention and Treatment of Substance Abuse (SAPT) in the State's Grant Accountability and Transparency Act (GATA) Audit Report Review Management System (ARRMS). The State of Illinois established the Grant Accountability Transparency Unit (GATU) to implement the provisions of GATA on a centralized basis. GATU has established standardized reporting requirements for subrecipients of the various Federal programs administered by the State through its various departments. Subrecipients of the State are required to certify whether they expended more than $750,000 in federal awards during the fiscal year and submit their single audit reporting packages to the Federal Audit Clearinghouse (if required). GATU is then responsible for obtaining the single audit reporting package, verifying the report meets the single audit requirements, and assigning, to the applicable state agency, any findings attributable to amounts passed through to the subrecipient(s) by the State and working with program personnel to issue management decisions on findings. The State utilizes a contractor to perform the centralized functions of obtaining the single audit report, verifying the report meets the requirements, and assigning findings to the applicable State agency. During our testing of subrecipient single audit desk review files for our 2023 major programs, we noted instances where single audit desk reviews were still in process and had not been finalized within GATA ARRMS as of the date of our testing (October 7, 2024). One subrecipient in our sample for the WIC program had incomplete single audit reviews for fiscal years 2019 through 2022, despite the fact the State had obtained the single audit report from the Federal Audit Clearinghouse for each of these fiscal years. Upon further review of data contained within GATA ARRMS, we identified 669 single audit reviews were identified as incomplete in GATA ARRMS for grantees who: (1) reported expenditures under fiscal year 2023 major programs, (2) had an audit report with a FAC acceptance date between January 2, 2022 and January 3, 2023 (requiring the report to be reviewed during fiscal year 2023) and (3) were not sanctioned (placed on the Illinois Stop Payment List) by the State for noncompliance with reporting requirements. These 669 reviews were in varying stages of completion with the majority (608 audits) pending documentation supporting the issuance of a final completion letter by the cognizant agency. The remaining 61 audits (9.1%) were pending receipt of documentation, pending a review, or had another error requiring follow-up. These 669 audits included 323 audits (48.3%) with one or more findings potentially requiring a management decision to be issued. We noted the cognizant agencies for the 669 incomplete single audit reviews in GATA ARRMS were as follows: "See Table in the Audit Report". The 669 incomplete single audit reviews in GATA ARRMS pertained to subrecipients of the following major programs: "See Table in the Audit Report". While in many instances there was evidence the State agencies had completed the necessary procedures outside of GATA ARRMS, the purpose of GATA ARRMS is to reduce the duplication of effort across State agencies and to provide a single submission point for the State’s subrecipients. The lack of monitoring controls around this centralized process may result in noncompliance with subrecipient single audit desk review requirements. The State’s subrecipient expenditures under the federal programs for the year ended June 30, 2023 were as follows: "See Table in the Audit Report". Criteria or Requirement: According to 2 CFR 200.332(d), a pass-through entity is required to monitor the activities of subrecipients as necessary to ensure the federal awards are used for authorized purposes in compliance with laws, regulations, and the provisions of contracts or grant agreements and that performance goals are achieved. Further, 2 CFR 200.332(d)(3) and 2 CFR 200.521 state that a pass-through entity is required to issue a management decision on audit findings within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC) and ensure that the subrecipient takes timely and appropriate corrective action on all audit findings. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, 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. Effective internal controls should include implementing procedures to monitor whether single audit reports are reviewed, management decision letters are issued, and single audit desk review files are closed out in GATA ARRMS in a timely manner. Cause: In discussing these conditions with GOMB officials, management stated that the incompleteness of the State’s audit reviews in GATA ARRMS was due to oversight. Possible Asserted Effect: Failure to complete and document reviews of subrecipient single audit reports in GATA ARRMS in a timely manner may result in noncompliance with the State’s obligation as a pass-through entity to appropriately monitor its subrecipients. Repeat Finding: A similar finding was not reported in the prior year audit (Finding Code 2023-002). Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend GOMB establish procedures to monitor the completion and documentation of single audit report reviews in GATA ARRMS to ensure the State complies with its obligation as a pass-through entity. Views of GOMB Officials: GOMB agrees with the finding.
State Agency: Illinois Governor’s Office of Management and Budget (GOMB) Federal Agency: U.S. Department of Agriculture (USDA), U.S. Department of Justice (DOJ), U.S. Department of Labor (DOL), U.S. Department of Transportation (DOT), U.S. Department of the Treasury (TREAS), U.S. Department of Education (ED), U.S. Department of Health and Human Services (USDHHS) Program Name: Special Supplemental Nutrition Program for Women, Infants and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program, WIOA Cluster, Highway Planning and Construction, Emergency Rental Assistance Program, Homeowner Assistance Fund Program, Coronavirus State and Local Fiscal Recovery Funds, Title I Grants to Local Educational Agencies, Twenty-First Century Community Learning Centers, Supporting Effective Instruction State Grants, Education Stabilization Fund (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families (TANF), Child Support Enforcement, Low-Income Home Energy Assistance Program, Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant, Block Grants for Prevention and Treatment of Substance Abuse ALN and Program Expenditures 10.557 ($168,740,425), 10.558 ($156,353,139), 16.575 ($78,196,419), 17.258/17.259/17.278 ($141,177,677), 20.205 ($1,932,300,419), 21.023 ($179,355,381), 21.026 ($177,107,928), 21.027 ($2,804,581,453), 84.010A ($704,235,726), 84.287 ($77,436,583),84.367A ($76,537,613), 84.425 ($2,227,152,891), 93.323 ($174,636,052), 93.558 ($578,867,422), 93.563 ($131,300,355), 93.568 ($288,503,657), 93.575/93.596 ($783,907,069), 93.667 ($57,147,970), 93.959 ($101,011,200) Award Numbers: Various – see table of award numbers Federal Award Year: Various – see table of award numbers Questioned Costs: None Finding 2023-002: Inadequate Monitoring of Subrecipient Single Audit Reviews Compliance Requirement: Subrecipient Monitoring Condition Found: The State of Illinois did not establish adequate controls to monitor the completion and documentation of the review single audit reports for its subrecipients of the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program (CVA), WIOA Cluster (WIOA), Highway and Planning Construction (Highway), Emergency Rental Assistance Program (ERAP), Homeowner Assistance Fund Program (HAF), Coronavirus State and Local Fiscal Recovery Funds (SLFRF), Twenty-First Century Community Learning Centers (Twenty-First), Title I Grants to Local Education Agencies (Title I), Supporting Effective Instruction State Grants (SEISG), Education Stabilization Funds (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families Cluster (TANF), Child Support Enforcement (CSE), Low-Income Home Energy Assistance Program (LIHEAP), Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant (SSBG), and Block Grants for Prevention and Treatment of Substance Abuse (SAPT) in the State's Grant Accountability and Transparency Act (GATA) Audit Report Review Management System (ARRMS). The State of Illinois established the Grant Accountability Transparency Unit (GATU) to implement the provisions of GATA on a centralized basis. GATU has established standardized reporting requirements for subrecipients of the various Federal programs administered by the State through its various departments. Subrecipients of the State are required to certify whether they expended more than $750,000 in federal awards during the fiscal year and submit their single audit reporting packages to the Federal Audit Clearinghouse (if required). GATU is then responsible for obtaining the single audit reporting package, verifying the report meets the single audit requirements, and assigning, to the applicable state agency, any findings attributable to amounts passed through to the subrecipient(s) by the State and working with program personnel to issue management decisions on findings. The State utilizes a contractor to perform the centralized functions of obtaining the single audit report, verifying the report meets the requirements, and assigning findings to the applicable State agency. During our testing of subrecipient single audit desk review files for our 2023 major programs, we noted instances where single audit desk reviews were still in process and had not been finalized within GATA ARRMS as of the date of our testing (October 7, 2024). One subrecipient in our sample for the WIC program had incomplete single audit reviews for fiscal years 2019 through 2022, despite the fact the State had obtained the single audit report from the Federal Audit Clearinghouse for each of these fiscal years. Upon further review of data contained within GATA ARRMS, we identified 669 single audit reviews were identified as incomplete in GATA ARRMS for grantees who: (1) reported expenditures under fiscal year 2023 major programs, (2) had an audit report with a FAC acceptance date between January 2, 2022 and January 3, 2023 (requiring the report to be reviewed during fiscal year 2023) and (3) were not sanctioned (placed on the Illinois Stop Payment List) by the State for noncompliance with reporting requirements. These 669 reviews were in varying stages of completion with the majority (608 audits) pending documentation supporting the issuance of a final completion letter by the cognizant agency. The remaining 61 audits (9.1%) were pending receipt of documentation, pending a review, or had another error requiring follow-up. These 669 audits included 323 audits (48.3%) with one or more findings potentially requiring a management decision to be issued. We noted the cognizant agencies for the 669 incomplete single audit reviews in GATA ARRMS were as follows: "See Table in the Audit Report". The 669 incomplete single audit reviews in GATA ARRMS pertained to subrecipients of the following major programs: "See Table in the Audit Report". While in many instances there was evidence the State agencies had completed the necessary procedures outside of GATA ARRMS, the purpose of GATA ARRMS is to reduce the duplication of effort across State agencies and to provide a single submission point for the State’s subrecipients. The lack of monitoring controls around this centralized process may result in noncompliance with subrecipient single audit desk review requirements. The State’s subrecipient expenditures under the federal programs for the year ended June 30, 2023 were as follows: "See Table in the Audit Report". Criteria or Requirement: According to 2 CFR 200.332(d), a pass-through entity is required to monitor the activities of subrecipients as necessary to ensure the federal awards are used for authorized purposes in compliance with laws, regulations, and the provisions of contracts or grant agreements and that performance goals are achieved. Further, 2 CFR 200.332(d)(3) and 2 CFR 200.521 state that a pass-through entity is required to issue a management decision on audit findings within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC) and ensure that the subrecipient takes timely and appropriate corrective action on all audit findings. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, 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. Effective internal controls should include implementing procedures to monitor whether single audit reports are reviewed, management decision letters are issued, and single audit desk review files are closed out in GATA ARRMS in a timely manner. Cause: In discussing these conditions with GOMB officials, management stated that the incompleteness of the State’s audit reviews in GATA ARRMS was due to oversight. Possible Asserted Effect: Failure to complete and document reviews of subrecipient single audit reports in GATA ARRMS in a timely manner may result in noncompliance with the State’s obligation as a pass-through entity to appropriately monitor its subrecipients. Repeat Finding: A similar finding was not reported in the prior year audit (Finding Code 2023-002). Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend GOMB establish procedures to monitor the completion and documentation of single audit report reviews in GATA ARRMS to ensure the State complies with its obligation as a pass-through entity. Views of GOMB Officials: GOMB agrees with the finding.
State Agency: Illinois Governor’s Office of Management and Budget (GOMB) Federal Agency: U.S. Department of Agriculture (USDA), U.S. Department of Justice (DOJ), U.S. Department of Labor (DOL), U.S. Department of Transportation (DOT), U.S. Department of the Treasury (TREAS), U.S. Department of Education (ED), U.S. Department of Health and Human Services (USDHHS) Program Name: Special Supplemental Nutrition Program for Women, Infants and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program, WIOA Cluster, Highway Planning and Construction, Emergency Rental Assistance Program, Homeowner Assistance Fund Program, Coronavirus State and Local Fiscal Recovery Funds, Title I Grants to Local Educational Agencies, Twenty-First Century Community Learning Centers, Supporting Effective Instruction State Grants, Education Stabilization Fund (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families (TANF), Child Support Enforcement, Low-Income Home Energy Assistance Program, Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant, Block Grants for Prevention and Treatment of Substance Abuse ALN and Program Expenditures 10.557 ($168,740,425), 10.558 ($156,353,139), 16.575 ($78,196,419), 17.258/17.259/17.278 ($141,177,677), 20.205 ($1,932,300,419), 21.023 ($179,355,381), 21.026 ($177,107,928), 21.027 ($2,804,581,453), 84.010A ($704,235,726), 84.287 ($77,436,583),84.367A ($76,537,613), 84.425 ($2,227,152,891), 93.323 ($174,636,052), 93.558 ($578,867,422), 93.563 ($131,300,355), 93.568 ($288,503,657), 93.575/93.596 ($783,907,069), 93.667 ($57,147,970), 93.959 ($101,011,200) Award Numbers: Various – see table of award numbers Federal Award Year: Various – see table of award numbers Questioned Costs: None Finding 2023-002: Inadequate Monitoring of Subrecipient Single Audit Reviews Compliance Requirement: Subrecipient Monitoring Condition Found: The State of Illinois did not establish adequate controls to monitor the completion and documentation of the review single audit reports for its subrecipients of the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program (CVA), WIOA Cluster (WIOA), Highway and Planning Construction (Highway), Emergency Rental Assistance Program (ERAP), Homeowner Assistance Fund Program (HAF), Coronavirus State and Local Fiscal Recovery Funds (SLFRF), Twenty-First Century Community Learning Centers (Twenty-First), Title I Grants to Local Education Agencies (Title I), Supporting Effective Instruction State Grants (SEISG), Education Stabilization Funds (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families Cluster (TANF), Child Support Enforcement (CSE), Low-Income Home Energy Assistance Program (LIHEAP), Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant (SSBG), and Block Grants for Prevention and Treatment of Substance Abuse (SAPT) in the State's Grant Accountability and Transparency Act (GATA) Audit Report Review Management System (ARRMS). The State of Illinois established the Grant Accountability Transparency Unit (GATU) to implement the provisions of GATA on a centralized basis. GATU has established standardized reporting requirements for subrecipients of the various Federal programs administered by the State through its various departments. Subrecipients of the State are required to certify whether they expended more than $750,000 in federal awards during the fiscal year and submit their single audit reporting packages to the Federal Audit Clearinghouse (if required). GATU is then responsible for obtaining the single audit reporting package, verifying the report meets the single audit requirements, and assigning, to the applicable state agency, any findings attributable to amounts passed through to the subrecipient(s) by the State and working with program personnel to issue management decisions on findings. The State utilizes a contractor to perform the centralized functions of obtaining the single audit report, verifying the report meets the requirements, and assigning findings to the applicable State agency. During our testing of subrecipient single audit desk review files for our 2023 major programs, we noted instances where single audit desk reviews were still in process and had not been finalized within GATA ARRMS as of the date of our testing (October 7, 2024). One subrecipient in our sample for the WIC program had incomplete single audit reviews for fiscal years 2019 through 2022, despite the fact the State had obtained the single audit report from the Federal Audit Clearinghouse for each of these fiscal years. Upon further review of data contained within GATA ARRMS, we identified 669 single audit reviews were identified as incomplete in GATA ARRMS for grantees who: (1) reported expenditures under fiscal year 2023 major programs, (2) had an audit report with a FAC acceptance date between January 2, 2022 and January 3, 2023 (requiring the report to be reviewed during fiscal year 2023) and (3) were not sanctioned (placed on the Illinois Stop Payment List) by the State for noncompliance with reporting requirements. These 669 reviews were in varying stages of completion with the majority (608 audits) pending documentation supporting the issuance of a final completion letter by the cognizant agency. The remaining 61 audits (9.1%) were pending receipt of documentation, pending a review, or had another error requiring follow-up. These 669 audits included 323 audits (48.3%) with one or more findings potentially requiring a management decision to be issued. We noted the cognizant agencies for the 669 incomplete single audit reviews in GATA ARRMS were as follows: "See Table in the Audit Report". The 669 incomplete single audit reviews in GATA ARRMS pertained to subrecipients of the following major programs: "See Table in the Audit Report". While in many instances there was evidence the State agencies had completed the necessary procedures outside of GATA ARRMS, the purpose of GATA ARRMS is to reduce the duplication of effort across State agencies and to provide a single submission point for the State’s subrecipients. The lack of monitoring controls around this centralized process may result in noncompliance with subrecipient single audit desk review requirements. The State’s subrecipient expenditures under the federal programs for the year ended June 30, 2023 were as follows: "See Table in the Audit Report". Criteria or Requirement: According to 2 CFR 200.332(d), a pass-through entity is required to monitor the activities of subrecipients as necessary to ensure the federal awards are used for authorized purposes in compliance with laws, regulations, and the provisions of contracts or grant agreements and that performance goals are achieved. Further, 2 CFR 200.332(d)(3) and 2 CFR 200.521 state that a pass-through entity is required to issue a management decision on audit findings within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC) and ensure that the subrecipient takes timely and appropriate corrective action on all audit findings. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, 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. Effective internal controls should include implementing procedures to monitor whether single audit reports are reviewed, management decision letters are issued, and single audit desk review files are closed out in GATA ARRMS in a timely manner. Cause: In discussing these conditions with GOMB officials, management stated that the incompleteness of the State’s audit reviews in GATA ARRMS was due to oversight. Possible Asserted Effect: Failure to complete and document reviews of subrecipient single audit reports in GATA ARRMS in a timely manner may result in noncompliance with the State’s obligation as a pass-through entity to appropriately monitor its subrecipients. Repeat Finding: A similar finding was not reported in the prior year audit (Finding Code 2023-002). Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend GOMB establish procedures to monitor the completion and documentation of single audit report reviews in GATA ARRMS to ensure the State complies with its obligation as a pass-through entity. Views of GOMB Officials: GOMB agrees with the finding.
State Agency: Illinois Governor’s Office of Management and Budget (GOMB) Federal Agency: U.S. Department of Agriculture (USDA), U.S. Department of Justice (DOJ), U.S. Department of Labor (DOL), U.S. Department of Transportation (DOT), U.S. Department of the Treasury (TREAS), U.S. Department of Education (ED), U.S. Department of Health and Human Services (USDHHS) Program Name: Special Supplemental Nutrition Program for Women, Infants and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program, WIOA Cluster, Highway Planning and Construction, Emergency Rental Assistance Program, Homeowner Assistance Fund Program, Coronavirus State and Local Fiscal Recovery Funds, Title I Grants to Local Educational Agencies, Twenty-First Century Community Learning Centers, Supporting Effective Instruction State Grants, Education Stabilization Fund (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families (TANF), Child Support Enforcement, Low-Income Home Energy Assistance Program, Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant, Block Grants for Prevention and Treatment of Substance Abuse ALN and Program Expenditures 10.557 ($168,740,425), 10.558 ($156,353,139), 16.575 ($78,196,419), 17.258/17.259/17.278 ($141,177,677), 20.205 ($1,932,300,419), 21.023 ($179,355,381), 21.026 ($177,107,928), 21.027 ($2,804,581,453), 84.010A ($704,235,726), 84.287 ($77,436,583),84.367A ($76,537,613), 84.425 ($2,227,152,891), 93.323 ($174,636,052), 93.558 ($578,867,422), 93.563 ($131,300,355), 93.568 ($288,503,657), 93.575/93.596 ($783,907,069), 93.667 ($57,147,970), 93.959 ($101,011,200) Award Numbers: Various – see table of award numbers Federal Award Year: Various – see table of award numbers Questioned Costs: None Finding 2023-002: Inadequate Monitoring of Subrecipient Single Audit Reviews Compliance Requirement: Subrecipient Monitoring Condition Found: The State of Illinois did not establish adequate controls to monitor the completion and documentation of the review single audit reports for its subrecipients of the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program (CVA), WIOA Cluster (WIOA), Highway and Planning Construction (Highway), Emergency Rental Assistance Program (ERAP), Homeowner Assistance Fund Program (HAF), Coronavirus State and Local Fiscal Recovery Funds (SLFRF), Twenty-First Century Community Learning Centers (Twenty-First), Title I Grants to Local Education Agencies (Title I), Supporting Effective Instruction State Grants (SEISG), Education Stabilization Funds (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families Cluster (TANF), Child Support Enforcement (CSE), Low-Income Home Energy Assistance Program (LIHEAP), Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant (SSBG), and Block Grants for Prevention and Treatment of Substance Abuse (SAPT) in the State's Grant Accountability and Transparency Act (GATA) Audit Report Review Management System (ARRMS). The State of Illinois established the Grant Accountability Transparency Unit (GATU) to implement the provisions of GATA on a centralized basis. GATU has established standardized reporting requirements for subrecipients of the various Federal programs administered by the State through its various departments. Subrecipients of the State are required to certify whether they expended more than $750,000 in federal awards during the fiscal year and submit their single audit reporting packages to the Federal Audit Clearinghouse (if required). GATU is then responsible for obtaining the single audit reporting package, verifying the report meets the single audit requirements, and assigning, to the applicable state agency, any findings attributable to amounts passed through to the subrecipient(s) by the State and working with program personnel to issue management decisions on findings. The State utilizes a contractor to perform the centralized functions of obtaining the single audit report, verifying the report meets the requirements, and assigning findings to the applicable State agency. During our testing of subrecipient single audit desk review files for our 2023 major programs, we noted instances where single audit desk reviews were still in process and had not been finalized within GATA ARRMS as of the date of our testing (October 7, 2024). One subrecipient in our sample for the WIC program had incomplete single audit reviews for fiscal years 2019 through 2022, despite the fact the State had obtained the single audit report from the Federal Audit Clearinghouse for each of these fiscal years. Upon further review of data contained within GATA ARRMS, we identified 669 single audit reviews were identified as incomplete in GATA ARRMS for grantees who: (1) reported expenditures under fiscal year 2023 major programs, (2) had an audit report with a FAC acceptance date between January 2, 2022 and January 3, 2023 (requiring the report to be reviewed during fiscal year 2023) and (3) were not sanctioned (placed on the Illinois Stop Payment List) by the State for noncompliance with reporting requirements. These 669 reviews were in varying stages of completion with the majority (608 audits) pending documentation supporting the issuance of a final completion letter by the cognizant agency. The remaining 61 audits (9.1%) were pending receipt of documentation, pending a review, or had another error requiring follow-up. These 669 audits included 323 audits (48.3%) with one or more findings potentially requiring a management decision to be issued. We noted the cognizant agencies for the 669 incomplete single audit reviews in GATA ARRMS were as follows: "See Table in the Audit Report". The 669 incomplete single audit reviews in GATA ARRMS pertained to subrecipients of the following major programs: "See Table in the Audit Report". While in many instances there was evidence the State agencies had completed the necessary procedures outside of GATA ARRMS, the purpose of GATA ARRMS is to reduce the duplication of effort across State agencies and to provide a single submission point for the State’s subrecipients. The lack of monitoring controls around this centralized process may result in noncompliance with subrecipient single audit desk review requirements. The State’s subrecipient expenditures under the federal programs for the year ended June 30, 2023 were as follows: "See Table in the Audit Report". Criteria or Requirement: According to 2 CFR 200.332(d), a pass-through entity is required to monitor the activities of subrecipients as necessary to ensure the federal awards are used for authorized purposes in compliance with laws, regulations, and the provisions of contracts or grant agreements and that performance goals are achieved. Further, 2 CFR 200.332(d)(3) and 2 CFR 200.521 state that a pass-through entity is required to issue a management decision on audit findings within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC) and ensure that the subrecipient takes timely and appropriate corrective action on all audit findings. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, 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. Effective internal controls should include implementing procedures to monitor whether single audit reports are reviewed, management decision letters are issued, and single audit desk review files are closed out in GATA ARRMS in a timely manner. Cause: In discussing these conditions with GOMB officials, management stated that the incompleteness of the State’s audit reviews in GATA ARRMS was due to oversight. Possible Asserted Effect: Failure to complete and document reviews of subrecipient single audit reports in GATA ARRMS in a timely manner may result in noncompliance with the State’s obligation as a pass-through entity to appropriately monitor its subrecipients. Repeat Finding: A similar finding was not reported in the prior year audit (Finding Code 2023-002). Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend GOMB establish procedures to monitor the completion and documentation of single audit report reviews in GATA ARRMS to ensure the State complies with its obligation as a pass-through entity. Views of GOMB Officials: GOMB agrees with the finding.
State Agency: Illinois Governor’s Office of Management and Budget (GOMB) Federal Agency: U.S. Department of Agriculture (USDA), U.S. Department of Justice (DOJ), U.S. Department of Labor (DOL), U.S. Department of Transportation (DOT), U.S. Department of the Treasury (TREAS), U.S. Department of Education (ED), U.S. Department of Health and Human Services (USDHHS) Program Name: Special Supplemental Nutrition Program for Women, Infants and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program, WIOA Cluster, Highway Planning and Construction, Emergency Rental Assistance Program, Homeowner Assistance Fund Program, Coronavirus State and Local Fiscal Recovery Funds, Title I Grants to Local Educational Agencies, Twenty-First Century Community Learning Centers, Supporting Effective Instruction State Grants, Education Stabilization Fund (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families (TANF), Child Support Enforcement, Low-Income Home Energy Assistance Program, Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant, Block Grants for Prevention and Treatment of Substance Abuse ALN and Program Expenditures 10.557 ($168,740,425), 10.558 ($156,353,139), 16.575 ($78,196,419), 17.258/17.259/17.278 ($141,177,677), 20.205 ($1,932,300,419), 21.023 ($179,355,381), 21.026 ($177,107,928), 21.027 ($2,804,581,453), 84.010A ($704,235,726), 84.287 ($77,436,583),84.367A ($76,537,613), 84.425 ($2,227,152,891), 93.323 ($174,636,052), 93.558 ($578,867,422), 93.563 ($131,300,355), 93.568 ($288,503,657), 93.575/93.596 ($783,907,069), 93.667 ($57,147,970), 93.959 ($101,011,200) Award Numbers: Various – see table of award numbers Federal Award Year: Various – see table of award numbers Questioned Costs: None Finding 2023-002: Inadequate Monitoring of Subrecipient Single Audit Reviews Compliance Requirement: Subrecipient Monitoring Condition Found: The State of Illinois did not establish adequate controls to monitor the completion and documentation of the review single audit reports for its subrecipients of the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program (CVA), WIOA Cluster (WIOA), Highway and Planning Construction (Highway), Emergency Rental Assistance Program (ERAP), Homeowner Assistance Fund Program (HAF), Coronavirus State and Local Fiscal Recovery Funds (SLFRF), Twenty-First Century Community Learning Centers (Twenty-First), Title I Grants to Local Education Agencies (Title I), Supporting Effective Instruction State Grants (SEISG), Education Stabilization Funds (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families Cluster (TANF), Child Support Enforcement (CSE), Low-Income Home Energy Assistance Program (LIHEAP), Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant (SSBG), and Block Grants for Prevention and Treatment of Substance Abuse (SAPT) in the State's Grant Accountability and Transparency Act (GATA) Audit Report Review Management System (ARRMS). The State of Illinois established the Grant Accountability Transparency Unit (GATU) to implement the provisions of GATA on a centralized basis. GATU has established standardized reporting requirements for subrecipients of the various Federal programs administered by the State through its various departments. Subrecipients of the State are required to certify whether they expended more than $750,000 in federal awards during the fiscal year and submit their single audit reporting packages to the Federal Audit Clearinghouse (if required). GATU is then responsible for obtaining the single audit reporting package, verifying the report meets the single audit requirements, and assigning, to the applicable state agency, any findings attributable to amounts passed through to the subrecipient(s) by the State and working with program personnel to issue management decisions on findings. The State utilizes a contractor to perform the centralized functions of obtaining the single audit report, verifying the report meets the requirements, and assigning findings to the applicable State agency. During our testing of subrecipient single audit desk review files for our 2023 major programs, we noted instances where single audit desk reviews were still in process and had not been finalized within GATA ARRMS as of the date of our testing (October 7, 2024). One subrecipient in our sample for the WIC program had incomplete single audit reviews for fiscal years 2019 through 2022, despite the fact the State had obtained the single audit report from the Federal Audit Clearinghouse for each of these fiscal years. Upon further review of data contained within GATA ARRMS, we identified 669 single audit reviews were identified as incomplete in GATA ARRMS for grantees who: (1) reported expenditures under fiscal year 2023 major programs, (2) had an audit report with a FAC acceptance date between January 2, 2022 and January 3, 2023 (requiring the report to be reviewed during fiscal year 2023) and (3) were not sanctioned (placed on the Illinois Stop Payment List) by the State for noncompliance with reporting requirements. These 669 reviews were in varying stages of completion with the majority (608 audits) pending documentation supporting the issuance of a final completion letter by the cognizant agency. The remaining 61 audits (9.1%) were pending receipt of documentation, pending a review, or had another error requiring follow-up. These 669 audits included 323 audits (48.3%) with one or more findings potentially requiring a management decision to be issued. We noted the cognizant agencies for the 669 incomplete single audit reviews in GATA ARRMS were as follows: "See Table in the Audit Report". The 669 incomplete single audit reviews in GATA ARRMS pertained to subrecipients of the following major programs: "See Table in the Audit Report". While in many instances there was evidence the State agencies had completed the necessary procedures outside of GATA ARRMS, the purpose of GATA ARRMS is to reduce the duplication of effort across State agencies and to provide a single submission point for the State’s subrecipients. The lack of monitoring controls around this centralized process may result in noncompliance with subrecipient single audit desk review requirements. The State’s subrecipient expenditures under the federal programs for the year ended June 30, 2023 were as follows: "See Table in the Audit Report". Criteria or Requirement: According to 2 CFR 200.332(d), a pass-through entity is required to monitor the activities of subrecipients as necessary to ensure the federal awards are used for authorized purposes in compliance with laws, regulations, and the provisions of contracts or grant agreements and that performance goals are achieved. Further, 2 CFR 200.332(d)(3) and 2 CFR 200.521 state that a pass-through entity is required to issue a management decision on audit findings within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC) and ensure that the subrecipient takes timely and appropriate corrective action on all audit findings. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, 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. Effective internal controls should include implementing procedures to monitor whether single audit reports are reviewed, management decision letters are issued, and single audit desk review files are closed out in GATA ARRMS in a timely manner. Cause: In discussing these conditions with GOMB officials, management stated that the incompleteness of the State’s audit reviews in GATA ARRMS was due to oversight. Possible Asserted Effect: Failure to complete and document reviews of subrecipient single audit reports in GATA ARRMS in a timely manner may result in noncompliance with the State’s obligation as a pass-through entity to appropriately monitor its subrecipients. Repeat Finding: A similar finding was not reported in the prior year audit (Finding Code 2023-002). Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend GOMB establish procedures to monitor the completion and documentation of single audit report reviews in GATA ARRMS to ensure the State complies with its obligation as a pass-through entity. Views of GOMB Officials: GOMB agrees with the finding.
State Agency: Illinois Governor’s Office of Management and Budget (GOMB) Federal Agency: U.S. Department of Agriculture (USDA), U.S. Department of Justice (DOJ), U.S. Department of Labor (DOL), U.S. Department of Transportation (DOT), U.S. Department of the Treasury (TREAS), U.S. Department of Education (ED), U.S. Department of Health and Human Services (USDHHS) Program Name: Special Supplemental Nutrition Program for Women, Infants and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program, WIOA Cluster, Highway Planning and Construction, Emergency Rental Assistance Program, Homeowner Assistance Fund Program, Coronavirus State and Local Fiscal Recovery Funds, Title I Grants to Local Educational Agencies, Twenty-First Century Community Learning Centers, Supporting Effective Instruction State Grants, Education Stabilization Fund (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families (TANF), Child Support Enforcement, Low-Income Home Energy Assistance Program, Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant, Block Grants for Prevention and Treatment of Substance Abuse ALN and Program Expenditures 10.557 ($168,740,425), 10.558 ($156,353,139), 16.575 ($78,196,419), 17.258/17.259/17.278 ($141,177,677), 20.205 ($1,932,300,419), 21.023 ($179,355,381), 21.026 ($177,107,928), 21.027 ($2,804,581,453), 84.010A ($704,235,726), 84.287 ($77,436,583),84.367A ($76,537,613), 84.425 ($2,227,152,891), 93.323 ($174,636,052), 93.558 ($578,867,422), 93.563 ($131,300,355), 93.568 ($288,503,657), 93.575/93.596 ($783,907,069), 93.667 ($57,147,970), 93.959 ($101,011,200) Award Numbers: Various – see table of award numbers Federal Award Year: Various – see table of award numbers Questioned Costs: None Finding 2023-002: Inadequate Monitoring of Subrecipient Single Audit Reviews Compliance Requirement: Subrecipient Monitoring Condition Found: The State of Illinois did not establish adequate controls to monitor the completion and documentation of the review single audit reports for its subrecipients of the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program (CVA), WIOA Cluster (WIOA), Highway and Planning Construction (Highway), Emergency Rental Assistance Program (ERAP), Homeowner Assistance Fund Program (HAF), Coronavirus State and Local Fiscal Recovery Funds (SLFRF), Twenty-First Century Community Learning Centers (Twenty-First), Title I Grants to Local Education Agencies (Title I), Supporting Effective Instruction State Grants (SEISG), Education Stabilization Funds (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families Cluster (TANF), Child Support Enforcement (CSE), Low-Income Home Energy Assistance Program (LIHEAP), Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant (SSBG), and Block Grants for Prevention and Treatment of Substance Abuse (SAPT) in the State's Grant Accountability and Transparency Act (GATA) Audit Report Review Management System (ARRMS). The State of Illinois established the Grant Accountability Transparency Unit (GATU) to implement the provisions of GATA on a centralized basis. GATU has established standardized reporting requirements for subrecipients of the various Federal programs administered by the State through its various departments. Subrecipients of the State are required to certify whether they expended more than $750,000 in federal awards during the fiscal year and submit their single audit reporting packages to the Federal Audit Clearinghouse (if required). GATU is then responsible for obtaining the single audit reporting package, verifying the report meets the single audit requirements, and assigning, to the applicable state agency, any findings attributable to amounts passed through to the subrecipient(s) by the State and working with program personnel to issue management decisions on findings. The State utilizes a contractor to perform the centralized functions of obtaining the single audit report, verifying the report meets the requirements, and assigning findings to the applicable State agency. During our testing of subrecipient single audit desk review files for our 2023 major programs, we noted instances where single audit desk reviews were still in process and had not been finalized within GATA ARRMS as of the date of our testing (October 7, 2024). One subrecipient in our sample for the WIC program had incomplete single audit reviews for fiscal years 2019 through 2022, despite the fact the State had obtained the single audit report from the Federal Audit Clearinghouse for each of these fiscal years. Upon further review of data contained within GATA ARRMS, we identified 669 single audit reviews were identified as incomplete in GATA ARRMS for grantees who: (1) reported expenditures under fiscal year 2023 major programs, (2) had an audit report with a FAC acceptance date between January 2, 2022 and January 3, 2023 (requiring the report to be reviewed during fiscal year 2023) and (3) were not sanctioned (placed on the Illinois Stop Payment List) by the State for noncompliance with reporting requirements. These 669 reviews were in varying stages of completion with the majority (608 audits) pending documentation supporting the issuance of a final completion letter by the cognizant agency. The remaining 61 audits (9.1%) were pending receipt of documentation, pending a review, or had another error requiring follow-up. These 669 audits included 323 audits (48.3%) with one or more findings potentially requiring a management decision to be issued. We noted the cognizant agencies for the 669 incomplete single audit reviews in GATA ARRMS were as follows: "See Table in the Audit Report". The 669 incomplete single audit reviews in GATA ARRMS pertained to subrecipients of the following major programs: "See Table in the Audit Report". While in many instances there was evidence the State agencies had completed the necessary procedures outside of GATA ARRMS, the purpose of GATA ARRMS is to reduce the duplication of effort across State agencies and to provide a single submission point for the State’s subrecipients. The lack of monitoring controls around this centralized process may result in noncompliance with subrecipient single audit desk review requirements. The State’s subrecipient expenditures under the federal programs for the year ended June 30, 2023 were as follows: "See Table in the Audit Report". Criteria or Requirement: According to 2 CFR 200.332(d), a pass-through entity is required to monitor the activities of subrecipients as necessary to ensure the federal awards are used for authorized purposes in compliance with laws, regulations, and the provisions of contracts or grant agreements and that performance goals are achieved. Further, 2 CFR 200.332(d)(3) and 2 CFR 200.521 state that a pass-through entity is required to issue a management decision on audit findings within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC) and ensure that the subrecipient takes timely and appropriate corrective action on all audit findings. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, 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. Effective internal controls should include implementing procedures to monitor whether single audit reports are reviewed, management decision letters are issued, and single audit desk review files are closed out in GATA ARRMS in a timely manner. Cause: In discussing these conditions with GOMB officials, management stated that the incompleteness of the State’s audit reviews in GATA ARRMS was due to oversight. Possible Asserted Effect: Failure to complete and document reviews of subrecipient single audit reports in GATA ARRMS in a timely manner may result in noncompliance with the State’s obligation as a pass-through entity to appropriately monitor its subrecipients. Repeat Finding: A similar finding was not reported in the prior year audit (Finding Code 2023-002). Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend GOMB establish procedures to monitor the completion and documentation of single audit report reviews in GATA ARRMS to ensure the State complies with its obligation as a pass-through entity. Views of GOMB Officials: GOMB agrees with the finding.
State Agency: Illinois Governor’s Office of Management and Budget (GOMB) Federal Agency: U.S. Department of Agriculture (USDA), U.S. Department of Justice (DOJ), U.S. Department of Labor (DOL), U.S. Department of Transportation (DOT), U.S. Department of the Treasury (TREAS), U.S. Department of Education (ED), U.S. Department of Health and Human Services (USDHHS) Program Name: Special Supplemental Nutrition Program for Women, Infants and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program, WIOA Cluster, Highway Planning and Construction, Emergency Rental Assistance Program, Homeowner Assistance Fund Program, Coronavirus State and Local Fiscal Recovery Funds, Title I Grants to Local Educational Agencies, Twenty-First Century Community Learning Centers, Supporting Effective Instruction State Grants, Education Stabilization Fund (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families (TANF), Child Support Enforcement, Low-Income Home Energy Assistance Program, Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant, Block Grants for Prevention and Treatment of Substance Abuse ALN and Program Expenditures 10.557 ($168,740,425), 10.558 ($156,353,139), 16.575 ($78,196,419), 17.258/17.259/17.278 ($141,177,677), 20.205 ($1,932,300,419), 21.023 ($179,355,381), 21.026 ($177,107,928), 21.027 ($2,804,581,453), 84.010A ($704,235,726), 84.287 ($77,436,583),84.367A ($76,537,613), 84.425 ($2,227,152,891), 93.323 ($174,636,052), 93.558 ($578,867,422), 93.563 ($131,300,355), 93.568 ($288,503,657), 93.575/93.596 ($783,907,069), 93.667 ($57,147,970), 93.959 ($101,011,200) Award Numbers: Various – see table of award numbers Federal Award Year: Various – see table of award numbers Questioned Costs: None Finding 2023-002: Inadequate Monitoring of Subrecipient Single Audit Reviews Compliance Requirement: Subrecipient Monitoring Condition Found: The State of Illinois did not establish adequate controls to monitor the completion and documentation of the review single audit reports for its subrecipients of the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program (CVA), WIOA Cluster (WIOA), Highway and Planning Construction (Highway), Emergency Rental Assistance Program (ERAP), Homeowner Assistance Fund Program (HAF), Coronavirus State and Local Fiscal Recovery Funds (SLFRF), Twenty-First Century Community Learning Centers (Twenty-First), Title I Grants to Local Education Agencies (Title I), Supporting Effective Instruction State Grants (SEISG), Education Stabilization Funds (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families Cluster (TANF), Child Support Enforcement (CSE), Low-Income Home Energy Assistance Program (LIHEAP), Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant (SSBG), and Block Grants for Prevention and Treatment of Substance Abuse (SAPT) in the State's Grant Accountability and Transparency Act (GATA) Audit Report Review Management System (ARRMS). The State of Illinois established the Grant Accountability Transparency Unit (GATU) to implement the provisions of GATA on a centralized basis. GATU has established standardized reporting requirements for subrecipients of the various Federal programs administered by the State through its various departments. Subrecipients of the State are required to certify whether they expended more than $750,000 in federal awards during the fiscal year and submit their single audit reporting packages to the Federal Audit Clearinghouse (if required). GATU is then responsible for obtaining the single audit reporting package, verifying the report meets the single audit requirements, and assigning, to the applicable state agency, any findings attributable to amounts passed through to the subrecipient(s) by the State and working with program personnel to issue management decisions on findings. The State utilizes a contractor to perform the centralized functions of obtaining the single audit report, verifying the report meets the requirements, and assigning findings to the applicable State agency. During our testing of subrecipient single audit desk review files for our 2023 major programs, we noted instances where single audit desk reviews were still in process and had not been finalized within GATA ARRMS as of the date of our testing (October 7, 2024). One subrecipient in our sample for the WIC program had incomplete single audit reviews for fiscal years 2019 through 2022, despite the fact the State had obtained the single audit report from the Federal Audit Clearinghouse for each of these fiscal years. Upon further review of data contained within GATA ARRMS, we identified 669 single audit reviews were identified as incomplete in GATA ARRMS for grantees who: (1) reported expenditures under fiscal year 2023 major programs, (2) had an audit report with a FAC acceptance date between January 2, 2022 and January 3, 2023 (requiring the report to be reviewed during fiscal year 2023) and (3) were not sanctioned (placed on the Illinois Stop Payment List) by the State for noncompliance with reporting requirements. These 669 reviews were in varying stages of completion with the majority (608 audits) pending documentation supporting the issuance of a final completion letter by the cognizant agency. The remaining 61 audits (9.1%) were pending receipt of documentation, pending a review, or had another error requiring follow-up. These 669 audits included 323 audits (48.3%) with one or more findings potentially requiring a management decision to be issued. We noted the cognizant agencies for the 669 incomplete single audit reviews in GATA ARRMS were as follows: "See Table in the Audit Report". The 669 incomplete single audit reviews in GATA ARRMS pertained to subrecipients of the following major programs: "See Table in the Audit Report". While in many instances there was evidence the State agencies had completed the necessary procedures outside of GATA ARRMS, the purpose of GATA ARRMS is to reduce the duplication of effort across State agencies and to provide a single submission point for the State’s subrecipients. The lack of monitoring controls around this centralized process may result in noncompliance with subrecipient single audit desk review requirements. The State’s subrecipient expenditures under the federal programs for the year ended June 30, 2023 were as follows: "See Table in the Audit Report". Criteria or Requirement: According to 2 CFR 200.332(d), a pass-through entity is required to monitor the activities of subrecipients as necessary to ensure the federal awards are used for authorized purposes in compliance with laws, regulations, and the provisions of contracts or grant agreements and that performance goals are achieved. Further, 2 CFR 200.332(d)(3) and 2 CFR 200.521 state that a pass-through entity is required to issue a management decision on audit findings within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC) and ensure that the subrecipient takes timely and appropriate corrective action on all audit findings. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, 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. Effective internal controls should include implementing procedures to monitor whether single audit reports are reviewed, management decision letters are issued, and single audit desk review files are closed out in GATA ARRMS in a timely manner. Cause: In discussing these conditions with GOMB officials, management stated that the incompleteness of the State’s audit reviews in GATA ARRMS was due to oversight. Possible Asserted Effect: Failure to complete and document reviews of subrecipient single audit reports in GATA ARRMS in a timely manner may result in noncompliance with the State’s obligation as a pass-through entity to appropriately monitor its subrecipients. Repeat Finding: A similar finding was not reported in the prior year audit (Finding Code 2023-002). Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend GOMB establish procedures to monitor the completion and documentation of single audit report reviews in GATA ARRMS to ensure the State complies with its obligation as a pass-through entity. Views of GOMB Officials: GOMB agrees with the finding.
State Agency: Illinois Governor’s Office of Management and Budget (GOMB) Federal Agency: U.S. Department of Agriculture (USDA), U.S. Department of Justice (DOJ), U.S. Department of Labor (DOL), U.S. Department of Transportation (DOT), U.S. Department of the Treasury (TREAS), U.S. Department of Education (ED), U.S. Department of Health and Human Services (USDHHS) Program Name: Special Supplemental Nutrition Program for Women, Infants and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program, WIOA Cluster, Highway Planning and Construction, Emergency Rental Assistance Program, Homeowner Assistance Fund Program, Coronavirus State and Local Fiscal Recovery Funds, Title I Grants to Local Educational Agencies, Twenty-First Century Community Learning Centers, Supporting Effective Instruction State Grants, Education Stabilization Fund (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families (TANF), Child Support Enforcement, Low-Income Home Energy Assistance Program, Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant, Block Grants for Prevention and Treatment of Substance Abuse ALN and Program Expenditures 10.557 ($168,740,425), 10.558 ($156,353,139), 16.575 ($78,196,419), 17.258/17.259/17.278 ($141,177,677), 20.205 ($1,932,300,419), 21.023 ($179,355,381), 21.026 ($177,107,928), 21.027 ($2,804,581,453), 84.010A ($704,235,726), 84.287 ($77,436,583),84.367A ($76,537,613), 84.425 ($2,227,152,891), 93.323 ($174,636,052), 93.558 ($578,867,422), 93.563 ($131,300,355), 93.568 ($288,503,657), 93.575/93.596 ($783,907,069), 93.667 ($57,147,970), 93.959 ($101,011,200) Award Numbers: Various – see table of award numbers Federal Award Year: Various – see table of award numbers Questioned Costs: None Finding 2023-002: Inadequate Monitoring of Subrecipient Single Audit Reviews Compliance Requirement: Subrecipient Monitoring Condition Found: The State of Illinois did not establish adequate controls to monitor the completion and documentation of the review single audit reports for its subrecipients of the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program (CVA), WIOA Cluster (WIOA), Highway and Planning Construction (Highway), Emergency Rental Assistance Program (ERAP), Homeowner Assistance Fund Program (HAF), Coronavirus State and Local Fiscal Recovery Funds (SLFRF), Twenty-First Century Community Learning Centers (Twenty-First), Title I Grants to Local Education Agencies (Title I), Supporting Effective Instruction State Grants (SEISG), Education Stabilization Funds (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families Cluster (TANF), Child Support Enforcement (CSE), Low-Income Home Energy Assistance Program (LIHEAP), Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant (SSBG), and Block Grants for Prevention and Treatment of Substance Abuse (SAPT) in the State's Grant Accountability and Transparency Act (GATA) Audit Report Review Management System (ARRMS). The State of Illinois established the Grant Accountability Transparency Unit (GATU) to implement the provisions of GATA on a centralized basis. GATU has established standardized reporting requirements for subrecipients of the various Federal programs administered by the State through its various departments. Subrecipients of the State are required to certify whether they expended more than $750,000 in federal awards during the fiscal year and submit their single audit reporting packages to the Federal Audit Clearinghouse (if required). GATU is then responsible for obtaining the single audit reporting package, verifying the report meets the single audit requirements, and assigning, to the applicable state agency, any findings attributable to amounts passed through to the subrecipient(s) by the State and working with program personnel to issue management decisions on findings. The State utilizes a contractor to perform the centralized functions of obtaining the single audit report, verifying the report meets the requirements, and assigning findings to the applicable State agency. During our testing of subrecipient single audit desk review files for our 2023 major programs, we noted instances where single audit desk reviews were still in process and had not been finalized within GATA ARRMS as of the date of our testing (October 7, 2024). One subrecipient in our sample for the WIC program had incomplete single audit reviews for fiscal years 2019 through 2022, despite the fact the State had obtained the single audit report from the Federal Audit Clearinghouse for each of these fiscal years. Upon further review of data contained within GATA ARRMS, we identified 669 single audit reviews were identified as incomplete in GATA ARRMS for grantees who: (1) reported expenditures under fiscal year 2023 major programs, (2) had an audit report with a FAC acceptance date between January 2, 2022 and January 3, 2023 (requiring the report to be reviewed during fiscal year 2023) and (3) were not sanctioned (placed on the Illinois Stop Payment List) by the State for noncompliance with reporting requirements. These 669 reviews were in varying stages of completion with the majority (608 audits) pending documentation supporting the issuance of a final completion letter by the cognizant agency. The remaining 61 audits (9.1%) were pending receipt of documentation, pending a review, or had another error requiring follow-up. These 669 audits included 323 audits (48.3%) with one or more findings potentially requiring a management decision to be issued. We noted the cognizant agencies for the 669 incomplete single audit reviews in GATA ARRMS were as follows: "See Table in the Audit Report". The 669 incomplete single audit reviews in GATA ARRMS pertained to subrecipients of the following major programs: "See Table in the Audit Report". While in many instances there was evidence the State agencies had completed the necessary procedures outside of GATA ARRMS, the purpose of GATA ARRMS is to reduce the duplication of effort across State agencies and to provide a single submission point for the State’s subrecipients. The lack of monitoring controls around this centralized process may result in noncompliance with subrecipient single audit desk review requirements. The State’s subrecipient expenditures under the federal programs for the year ended June 30, 2023 were as follows: "See Table in the Audit Report". Criteria or Requirement: According to 2 CFR 200.332(d), a pass-through entity is required to monitor the activities of subrecipients as necessary to ensure the federal awards are used for authorized purposes in compliance with laws, regulations, and the provisions of contracts or grant agreements and that performance goals are achieved. Further, 2 CFR 200.332(d)(3) and 2 CFR 200.521 state that a pass-through entity is required to issue a management decision on audit findings within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC) and ensure that the subrecipient takes timely and appropriate corrective action on all audit findings. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, 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. Effective internal controls should include implementing procedures to monitor whether single audit reports are reviewed, management decision letters are issued, and single audit desk review files are closed out in GATA ARRMS in a timely manner. Cause: In discussing these conditions with GOMB officials, management stated that the incompleteness of the State’s audit reviews in GATA ARRMS was due to oversight. Possible Asserted Effect: Failure to complete and document reviews of subrecipient single audit reports in GATA ARRMS in a timely manner may result in noncompliance with the State’s obligation as a pass-through entity to appropriately monitor its subrecipients. Repeat Finding: A similar finding was not reported in the prior year audit (Finding Code 2023-002). Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend GOMB establish procedures to monitor the completion and documentation of single audit report reviews in GATA ARRMS to ensure the State complies with its obligation as a pass-through entity. Views of GOMB Officials: GOMB agrees with the finding.
State Agency: Illinois Governor’s Office of Management and Budget (GOMB) Federal Agency: U.S. Department of Agriculture (USDA), U.S. Department of Justice (DOJ), U.S. Department of Labor (DOL), U.S. Department of Transportation (DOT), U.S. Department of the Treasury (TREAS), U.S. Department of Education (ED), U.S. Department of Health and Human Services (USDHHS) Program Name: Special Supplemental Nutrition Program for Women, Infants and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program, WIOA Cluster, Highway Planning and Construction, Emergency Rental Assistance Program, Homeowner Assistance Fund Program, Coronavirus State and Local Fiscal Recovery Funds, Title I Grants to Local Educational Agencies, Twenty-First Century Community Learning Centers, Supporting Effective Instruction State Grants, Education Stabilization Fund (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families (TANF), Child Support Enforcement, Low-Income Home Energy Assistance Program, Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant, Block Grants for Prevention and Treatment of Substance Abuse ALN and Program Expenditures 10.557 ($168,740,425), 10.558 ($156,353,139), 16.575 ($78,196,419), 17.258/17.259/17.278 ($141,177,677), 20.205 ($1,932,300,419), 21.023 ($179,355,381), 21.026 ($177,107,928), 21.027 ($2,804,581,453), 84.010A ($704,235,726), 84.287 ($77,436,583),84.367A ($76,537,613), 84.425 ($2,227,152,891), 93.323 ($174,636,052), 93.558 ($578,867,422), 93.563 ($131,300,355), 93.568 ($288,503,657), 93.575/93.596 ($783,907,069), 93.667 ($57,147,970), 93.959 ($101,011,200) Award Numbers: Various – see table of award numbers Federal Award Year: Various – see table of award numbers Questioned Costs: None Finding 2023-002: Inadequate Monitoring of Subrecipient Single Audit Reviews Compliance Requirement: Subrecipient Monitoring Condition Found: The State of Illinois did not establish adequate controls to monitor the completion and documentation of the review single audit reports for its subrecipients of the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program (CVA), WIOA Cluster (WIOA), Highway and Planning Construction (Highway), Emergency Rental Assistance Program (ERAP), Homeowner Assistance Fund Program (HAF), Coronavirus State and Local Fiscal Recovery Funds (SLFRF), Twenty-First Century Community Learning Centers (Twenty-First), Title I Grants to Local Education Agencies (Title I), Supporting Effective Instruction State Grants (SEISG), Education Stabilization Funds (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families Cluster (TANF), Child Support Enforcement (CSE), Low-Income Home Energy Assistance Program (LIHEAP), Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant (SSBG), and Block Grants for Prevention and Treatment of Substance Abuse (SAPT) in the State's Grant Accountability and Transparency Act (GATA) Audit Report Review Management System (ARRMS). The State of Illinois established the Grant Accountability Transparency Unit (GATU) to implement the provisions of GATA on a centralized basis. GATU has established standardized reporting requirements for subrecipients of the various Federal programs administered by the State through its various departments. Subrecipients of the State are required to certify whether they expended more than $750,000 in federal awards during the fiscal year and submit their single audit reporting packages to the Federal Audit Clearinghouse (if required). GATU is then responsible for obtaining the single audit reporting package, verifying the report meets the single audit requirements, and assigning, to the applicable state agency, any findings attributable to amounts passed through to the subrecipient(s) by the State and working with program personnel to issue management decisions on findings. The State utilizes a contractor to perform the centralized functions of obtaining the single audit report, verifying the report meets the requirements, and assigning findings to the applicable State agency. During our testing of subrecipient single audit desk review files for our 2023 major programs, we noted instances where single audit desk reviews were still in process and had not been finalized within GATA ARRMS as of the date of our testing (October 7, 2024). One subrecipient in our sample for the WIC program had incomplete single audit reviews for fiscal years 2019 through 2022, despite the fact the State had obtained the single audit report from the Federal Audit Clearinghouse for each of these fiscal years. Upon further review of data contained within GATA ARRMS, we identified 669 single audit reviews were identified as incomplete in GATA ARRMS for grantees who: (1) reported expenditures under fiscal year 2023 major programs, (2) had an audit report with a FAC acceptance date between January 2, 2022 and January 3, 2023 (requiring the report to be reviewed during fiscal year 2023) and (3) were not sanctioned (placed on the Illinois Stop Payment List) by the State for noncompliance with reporting requirements. These 669 reviews were in varying stages of completion with the majority (608 audits) pending documentation supporting the issuance of a final completion letter by the cognizant agency. The remaining 61 audits (9.1%) were pending receipt of documentation, pending a review, or had another error requiring follow-up. These 669 audits included 323 audits (48.3%) with one or more findings potentially requiring a management decision to be issued. We noted the cognizant agencies for the 669 incomplete single audit reviews in GATA ARRMS were as follows: "See Table in the Audit Report". The 669 incomplete single audit reviews in GATA ARRMS pertained to subrecipients of the following major programs: "See Table in the Audit Report". While in many instances there was evidence the State agencies had completed the necessary procedures outside of GATA ARRMS, the purpose of GATA ARRMS is to reduce the duplication of effort across State agencies and to provide a single submission point for the State’s subrecipients. The lack of monitoring controls around this centralized process may result in noncompliance with subrecipient single audit desk review requirements. The State’s subrecipient expenditures under the federal programs for the year ended June 30, 2023 were as follows: "See Table in the Audit Report". Criteria or Requirement: According to 2 CFR 200.332(d), a pass-through entity is required to monitor the activities of subrecipients as necessary to ensure the federal awards are used for authorized purposes in compliance with laws, regulations, and the provisions of contracts or grant agreements and that performance goals are achieved. Further, 2 CFR 200.332(d)(3) and 2 CFR 200.521 state that a pass-through entity is required to issue a management decision on audit findings within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC) and ensure that the subrecipient takes timely and appropriate corrective action on all audit findings. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, 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. Effective internal controls should include implementing procedures to monitor whether single audit reports are reviewed, management decision letters are issued, and single audit desk review files are closed out in GATA ARRMS in a timely manner. Cause: In discussing these conditions with GOMB officials, management stated that the incompleteness of the State’s audit reviews in GATA ARRMS was due to oversight. Possible Asserted Effect: Failure to complete and document reviews of subrecipient single audit reports in GATA ARRMS in a timely manner may result in noncompliance with the State’s obligation as a pass-through entity to appropriately monitor its subrecipients. Repeat Finding: A similar finding was not reported in the prior year audit (Finding Code 2023-002). Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend GOMB establish procedures to monitor the completion and documentation of single audit report reviews in GATA ARRMS to ensure the State complies with its obligation as a pass-through entity. Views of GOMB Officials: GOMB agrees with the finding.
State Agency: Illinois Governor’s Office of Management and Budget (GOMB) Federal Agency: U.S. Department of Agriculture (USDA), U.S. Department of Justice (DOJ), U.S. Department of Labor (DOL), U.S. Department of Transportation (DOT), U.S. Department of the Treasury (TREAS), U.S. Department of Education (ED), U.S. Department of Health and Human Services (USDHHS) Program Name: Special Supplemental Nutrition Program for Women, Infants and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program, WIOA Cluster, Highway Planning and Construction, Emergency Rental Assistance Program, Homeowner Assistance Fund Program, Coronavirus State and Local Fiscal Recovery Funds, Title I Grants to Local Educational Agencies, Twenty-First Century Community Learning Centers, Supporting Effective Instruction State Grants, Education Stabilization Fund (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families (TANF), Child Support Enforcement, Low-Income Home Energy Assistance Program, Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant, Block Grants for Prevention and Treatment of Substance Abuse ALN and Program Expenditures 10.557 ($168,740,425), 10.558 ($156,353,139), 16.575 ($78,196,419), 17.258/17.259/17.278 ($141,177,677), 20.205 ($1,932,300,419), 21.023 ($179,355,381), 21.026 ($177,107,928), 21.027 ($2,804,581,453), 84.010A ($704,235,726), 84.287 ($77,436,583),84.367A ($76,537,613), 84.425 ($2,227,152,891), 93.323 ($174,636,052), 93.558 ($578,867,422), 93.563 ($131,300,355), 93.568 ($288,503,657), 93.575/93.596 ($783,907,069), 93.667 ($57,147,970), 93.959 ($101,011,200) Award Numbers: Various – see table of award numbers Federal Award Year: Various – see table of award numbers Questioned Costs: None Finding 2023-002: Inadequate Monitoring of Subrecipient Single Audit Reviews Compliance Requirement: Subrecipient Monitoring Condition Found: The State of Illinois did not establish adequate controls to monitor the completion and documentation of the review single audit reports for its subrecipients of the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program (CVA), WIOA Cluster (WIOA), Highway and Planning Construction (Highway), Emergency Rental Assistance Program (ERAP), Homeowner Assistance Fund Program (HAF), Coronavirus State and Local Fiscal Recovery Funds (SLFRF), Twenty-First Century Community Learning Centers (Twenty-First), Title I Grants to Local Education Agencies (Title I), Supporting Effective Instruction State Grants (SEISG), Education Stabilization Funds (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families Cluster (TANF), Child Support Enforcement (CSE), Low-Income Home Energy Assistance Program (LIHEAP), Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant (SSBG), and Block Grants for Prevention and Treatment of Substance Abuse (SAPT) in the State's Grant Accountability and Transparency Act (GATA) Audit Report Review Management System (ARRMS). The State of Illinois established the Grant Accountability Transparency Unit (GATU) to implement the provisions of GATA on a centralized basis. GATU has established standardized reporting requirements for subrecipients of the various Federal programs administered by the State through its various departments. Subrecipients of the State are required to certify whether they expended more than $750,000 in federal awards during the fiscal year and submit their single audit reporting packages to the Federal Audit Clearinghouse (if required). GATU is then responsible for obtaining the single audit reporting package, verifying the report meets the single audit requirements, and assigning, to the applicable state agency, any findings attributable to amounts passed through to the subrecipient(s) by the State and working with program personnel to issue management decisions on findings. The State utilizes a contractor to perform the centralized functions of obtaining the single audit report, verifying the report meets the requirements, and assigning findings to the applicable State agency. During our testing of subrecipient single audit desk review files for our 2023 major programs, we noted instances where single audit desk reviews were still in process and had not been finalized within GATA ARRMS as of the date of our testing (October 7, 2024). One subrecipient in our sample for the WIC program had incomplete single audit reviews for fiscal years 2019 through 2022, despite the fact the State had obtained the single audit report from the Federal Audit Clearinghouse for each of these fiscal years. Upon further review of data contained within GATA ARRMS, we identified 669 single audit reviews were identified as incomplete in GATA ARRMS for grantees who: (1) reported expenditures under fiscal year 2023 major programs, (2) had an audit report with a FAC acceptance date between January 2, 2022 and January 3, 2023 (requiring the report to be reviewed during fiscal year 2023) and (3) were not sanctioned (placed on the Illinois Stop Payment List) by the State for noncompliance with reporting requirements. These 669 reviews were in varying stages of completion with the majority (608 audits) pending documentation supporting the issuance of a final completion letter by the cognizant agency. The remaining 61 audits (9.1%) were pending receipt of documentation, pending a review, or had another error requiring follow-up. These 669 audits included 323 audits (48.3%) with one or more findings potentially requiring a management decision to be issued. We noted the cognizant agencies for the 669 incomplete single audit reviews in GATA ARRMS were as follows: "See Table in the Audit Report". The 669 incomplete single audit reviews in GATA ARRMS pertained to subrecipients of the following major programs: "See Table in the Audit Report". While in many instances there was evidence the State agencies had completed the necessary procedures outside of GATA ARRMS, the purpose of GATA ARRMS is to reduce the duplication of effort across State agencies and to provide a single submission point for the State’s subrecipients. The lack of monitoring controls around this centralized process may result in noncompliance with subrecipient single audit desk review requirements. The State’s subrecipient expenditures under the federal programs for the year ended June 30, 2023 were as follows: "See Table in the Audit Report". Criteria or Requirement: According to 2 CFR 200.332(d), a pass-through entity is required to monitor the activities of subrecipients as necessary to ensure the federal awards are used for authorized purposes in compliance with laws, regulations, and the provisions of contracts or grant agreements and that performance goals are achieved. Further, 2 CFR 200.332(d)(3) and 2 CFR 200.521 state that a pass-through entity is required to issue a management decision on audit findings within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC) and ensure that the subrecipient takes timely and appropriate corrective action on all audit findings. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, 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. Effective internal controls should include implementing procedures to monitor whether single audit reports are reviewed, management decision letters are issued, and single audit desk review files are closed out in GATA ARRMS in a timely manner. Cause: In discussing these conditions with GOMB officials, management stated that the incompleteness of the State’s audit reviews in GATA ARRMS was due to oversight. Possible Asserted Effect: Failure to complete and document reviews of subrecipient single audit reports in GATA ARRMS in a timely manner may result in noncompliance with the State’s obligation as a pass-through entity to appropriately monitor its subrecipients. Repeat Finding: A similar finding was not reported in the prior year audit (Finding Code 2023-002). Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend GOMB establish procedures to monitor the completion and documentation of single audit report reviews in GATA ARRMS to ensure the State complies with its obligation as a pass-through entity. Views of GOMB Officials: GOMB agrees with the finding.
State Agency: Illinois Governor’s Office of Management and Budget (GOMB) Federal Agency: U.S. Department of Agriculture (USDA), U.S. Department of Justice (DOJ), U.S. Department of Labor (DOL), U.S. Department of Transportation (DOT), U.S. Department of the Treasury (TREAS), U.S. Department of Education (ED), U.S. Department of Health and Human Services (USDHHS) Program Name: Special Supplemental Nutrition Program for Women, Infants and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program, WIOA Cluster, Highway Planning and Construction, Emergency Rental Assistance Program, Homeowner Assistance Fund Program, Coronavirus State and Local Fiscal Recovery Funds, Title I Grants to Local Educational Agencies, Twenty-First Century Community Learning Centers, Supporting Effective Instruction State Grants, Education Stabilization Fund (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families (TANF), Child Support Enforcement, Low-Income Home Energy Assistance Program, Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant, Block Grants for Prevention and Treatment of Substance Abuse ALN and Program Expenditures 10.557 ($168,740,425), 10.558 ($156,353,139), 16.575 ($78,196,419), 17.258/17.259/17.278 ($141,177,677), 20.205 ($1,932,300,419), 21.023 ($179,355,381), 21.026 ($177,107,928), 21.027 ($2,804,581,453), 84.010A ($704,235,726), 84.287 ($77,436,583),84.367A ($76,537,613), 84.425 ($2,227,152,891), 93.323 ($174,636,052), 93.558 ($578,867,422), 93.563 ($131,300,355), 93.568 ($288,503,657), 93.575/93.596 ($783,907,069), 93.667 ($57,147,970), 93.959 ($101,011,200) Award Numbers: Various – see table of award numbers Federal Award Year: Various – see table of award numbers Questioned Costs: None Finding 2023-002: Inadequate Monitoring of Subrecipient Single Audit Reviews Compliance Requirement: Subrecipient Monitoring Condition Found: The State of Illinois did not establish adequate controls to monitor the completion and documentation of the review single audit reports for its subrecipients of the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program (CVA), WIOA Cluster (WIOA), Highway and Planning Construction (Highway), Emergency Rental Assistance Program (ERAP), Homeowner Assistance Fund Program (HAF), Coronavirus State and Local Fiscal Recovery Funds (SLFRF), Twenty-First Century Community Learning Centers (Twenty-First), Title I Grants to Local Education Agencies (Title I), Supporting Effective Instruction State Grants (SEISG), Education Stabilization Funds (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families Cluster (TANF), Child Support Enforcement (CSE), Low-Income Home Energy Assistance Program (LIHEAP), Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant (SSBG), and Block Grants for Prevention and Treatment of Substance Abuse (SAPT) in the State's Grant Accountability and Transparency Act (GATA) Audit Report Review Management System (ARRMS). The State of Illinois established the Grant Accountability Transparency Unit (GATU) to implement the provisions of GATA on a centralized basis. GATU has established standardized reporting requirements for subrecipients of the various Federal programs administered by the State through its various departments. Subrecipients of the State are required to certify whether they expended more than $750,000 in federal awards during the fiscal year and submit their single audit reporting packages to the Federal Audit Clearinghouse (if required). GATU is then responsible for obtaining the single audit reporting package, verifying the report meets the single audit requirements, and assigning, to the applicable state agency, any findings attributable to amounts passed through to the subrecipient(s) by the State and working with program personnel to issue management decisions on findings. The State utilizes a contractor to perform the centralized functions of obtaining the single audit report, verifying the report meets the requirements, and assigning findings to the applicable State agency. During our testing of subrecipient single audit desk review files for our 2023 major programs, we noted instances where single audit desk reviews were still in process and had not been finalized within GATA ARRMS as of the date of our testing (October 7, 2024). One subrecipient in our sample for the WIC program had incomplete single audit reviews for fiscal years 2019 through 2022, despite the fact the State had obtained the single audit report from the Federal Audit Clearinghouse for each of these fiscal years. Upon further review of data contained within GATA ARRMS, we identified 669 single audit reviews were identified as incomplete in GATA ARRMS for grantees who: (1) reported expenditures under fiscal year 2023 major programs, (2) had an audit report with a FAC acceptance date between January 2, 2022 and January 3, 2023 (requiring the report to be reviewed during fiscal year 2023) and (3) were not sanctioned (placed on the Illinois Stop Payment List) by the State for noncompliance with reporting requirements. These 669 reviews were in varying stages of completion with the majority (608 audits) pending documentation supporting the issuance of a final completion letter by the cognizant agency. The remaining 61 audits (9.1%) were pending receipt of documentation, pending a review, or had another error requiring follow-up. These 669 audits included 323 audits (48.3%) with one or more findings potentially requiring a management decision to be issued. We noted the cognizant agencies for the 669 incomplete single audit reviews in GATA ARRMS were as follows: "See Table in the Audit Report". The 669 incomplete single audit reviews in GATA ARRMS pertained to subrecipients of the following major programs: "See Table in the Audit Report". While in many instances there was evidence the State agencies had completed the necessary procedures outside of GATA ARRMS, the purpose of GATA ARRMS is to reduce the duplication of effort across State agencies and to provide a single submission point for the State’s subrecipients. The lack of monitoring controls around this centralized process may result in noncompliance with subrecipient single audit desk review requirements. The State’s subrecipient expenditures under the federal programs for the year ended June 30, 2023 were as follows: "See Table in the Audit Report". Criteria or Requirement: According to 2 CFR 200.332(d), a pass-through entity is required to monitor the activities of subrecipients as necessary to ensure the federal awards are used for authorized purposes in compliance with laws, regulations, and the provisions of contracts or grant agreements and that performance goals are achieved. Further, 2 CFR 200.332(d)(3) and 2 CFR 200.521 state that a pass-through entity is required to issue a management decision on audit findings within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC) and ensure that the subrecipient takes timely and appropriate corrective action on all audit findings. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, 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. Effective internal controls should include implementing procedures to monitor whether single audit reports are reviewed, management decision letters are issued, and single audit desk review files are closed out in GATA ARRMS in a timely manner. Cause: In discussing these conditions with GOMB officials, management stated that the incompleteness of the State’s audit reviews in GATA ARRMS was due to oversight. Possible Asserted Effect: Failure to complete and document reviews of subrecipient single audit reports in GATA ARRMS in a timely manner may result in noncompliance with the State’s obligation as a pass-through entity to appropriately monitor its subrecipients. Repeat Finding: A similar finding was not reported in the prior year audit (Finding Code 2023-002). Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend GOMB establish procedures to monitor the completion and documentation of single audit report reviews in GATA ARRMS to ensure the State complies with its obligation as a pass-through entity. Views of GOMB Officials: GOMB agrees with the finding.
State Agency: Illinois Governor’s Office of Management and Budget (GOMB) Federal Agency: U.S. Department of Agriculture (USDA), U.S. Department of Justice (DOJ), U.S. Department of Labor (DOL), U.S. Department of Transportation (DOT), U.S. Department of the Treasury (TREAS), U.S. Department of Education (ED), U.S. Department of Health and Human Services (USDHHS) Program Name: Special Supplemental Nutrition Program for Women, Infants and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program, WIOA Cluster, Highway Planning and Construction, Emergency Rental Assistance Program, Homeowner Assistance Fund Program, Coronavirus State and Local Fiscal Recovery Funds, Title I Grants to Local Educational Agencies, Twenty-First Century Community Learning Centers, Supporting Effective Instruction State Grants, Education Stabilization Fund (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families (TANF), Child Support Enforcement, Low-Income Home Energy Assistance Program, Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant, Block Grants for Prevention and Treatment of Substance Abuse ALN and Program Expenditures 10.557 ($168,740,425), 10.558 ($156,353,139), 16.575 ($78,196,419), 17.258/17.259/17.278 ($141,177,677), 20.205 ($1,932,300,419), 21.023 ($179,355,381), 21.026 ($177,107,928), 21.027 ($2,804,581,453), 84.010A ($704,235,726), 84.287 ($77,436,583),84.367A ($76,537,613), 84.425 ($2,227,152,891), 93.323 ($174,636,052), 93.558 ($578,867,422), 93.563 ($131,300,355), 93.568 ($288,503,657), 93.575/93.596 ($783,907,069), 93.667 ($57,147,970), 93.959 ($101,011,200) Award Numbers: Various – see table of award numbers Federal Award Year: Various – see table of award numbers Questioned Costs: None Finding 2023-002: Inadequate Monitoring of Subrecipient Single Audit Reviews Compliance Requirement: Subrecipient Monitoring Condition Found: The State of Illinois did not establish adequate controls to monitor the completion and documentation of the review single audit reports for its subrecipients of the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program (CVA), WIOA Cluster (WIOA), Highway and Planning Construction (Highway), Emergency Rental Assistance Program (ERAP), Homeowner Assistance Fund Program (HAF), Coronavirus State and Local Fiscal Recovery Funds (SLFRF), Twenty-First Century Community Learning Centers (Twenty-First), Title I Grants to Local Education Agencies (Title I), Supporting Effective Instruction State Grants (SEISG), Education Stabilization Funds (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families Cluster (TANF), Child Support Enforcement (CSE), Low-Income Home Energy Assistance Program (LIHEAP), Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant (SSBG), and Block Grants for Prevention and Treatment of Substance Abuse (SAPT) in the State's Grant Accountability and Transparency Act (GATA) Audit Report Review Management System (ARRMS). The State of Illinois established the Grant Accountability Transparency Unit (GATU) to implement the provisions of GATA on a centralized basis. GATU has established standardized reporting requirements for subrecipients of the various Federal programs administered by the State through its various departments. Subrecipients of the State are required to certify whether they expended more than $750,000 in federal awards during the fiscal year and submit their single audit reporting packages to the Federal Audit Clearinghouse (if required). GATU is then responsible for obtaining the single audit reporting package, verifying the report meets the single audit requirements, and assigning, to the applicable state agency, any findings attributable to amounts passed through to the subrecipient(s) by the State and working with program personnel to issue management decisions on findings. The State utilizes a contractor to perform the centralized functions of obtaining the single audit report, verifying the report meets the requirements, and assigning findings to the applicable State agency. During our testing of subrecipient single audit desk review files for our 2023 major programs, we noted instances where single audit desk reviews were still in process and had not been finalized within GATA ARRMS as of the date of our testing (October 7, 2024). One subrecipient in our sample for the WIC program had incomplete single audit reviews for fiscal years 2019 through 2022, despite the fact the State had obtained the single audit report from the Federal Audit Clearinghouse for each of these fiscal years. Upon further review of data contained within GATA ARRMS, we identified 669 single audit reviews were identified as incomplete in GATA ARRMS for grantees who: (1) reported expenditures under fiscal year 2023 major programs, (2) had an audit report with a FAC acceptance date between January 2, 2022 and January 3, 2023 (requiring the report to be reviewed during fiscal year 2023) and (3) were not sanctioned (placed on the Illinois Stop Payment List) by the State for noncompliance with reporting requirements. These 669 reviews were in varying stages of completion with the majority (608 audits) pending documentation supporting the issuance of a final completion letter by the cognizant agency. The remaining 61 audits (9.1%) were pending receipt of documentation, pending a review, or had another error requiring follow-up. These 669 audits included 323 audits (48.3%) with one or more findings potentially requiring a management decision to be issued. We noted the cognizant agencies for the 669 incomplete single audit reviews in GATA ARRMS were as follows: "See Table in the Audit Report". The 669 incomplete single audit reviews in GATA ARRMS pertained to subrecipients of the following major programs: "See Table in the Audit Report". While in many instances there was evidence the State agencies had completed the necessary procedures outside of GATA ARRMS, the purpose of GATA ARRMS is to reduce the duplication of effort across State agencies and to provide a single submission point for the State’s subrecipients. The lack of monitoring controls around this centralized process may result in noncompliance with subrecipient single audit desk review requirements. The State’s subrecipient expenditures under the federal programs for the year ended June 30, 2023 were as follows: "See Table in the Audit Report". Criteria or Requirement: According to 2 CFR 200.332(d), a pass-through entity is required to monitor the activities of subrecipients as necessary to ensure the federal awards are used for authorized purposes in compliance with laws, regulations, and the provisions of contracts or grant agreements and that performance goals are achieved. Further, 2 CFR 200.332(d)(3) and 2 CFR 200.521 state that a pass-through entity is required to issue a management decision on audit findings within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC) and ensure that the subrecipient takes timely and appropriate corrective action on all audit findings. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, 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. Effective internal controls should include implementing procedures to monitor whether single audit reports are reviewed, management decision letters are issued, and single audit desk review files are closed out in GATA ARRMS in a timely manner. Cause: In discussing these conditions with GOMB officials, management stated that the incompleteness of the State’s audit reviews in GATA ARRMS was due to oversight. Possible Asserted Effect: Failure to complete and document reviews of subrecipient single audit reports in GATA ARRMS in a timely manner may result in noncompliance with the State’s obligation as a pass-through entity to appropriately monitor its subrecipients. Repeat Finding: A similar finding was not reported in the prior year audit (Finding Code 2023-002). Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend GOMB establish procedures to monitor the completion and documentation of single audit report reviews in GATA ARRMS to ensure the State complies with its obligation as a pass-through entity. Views of GOMB Officials: GOMB agrees with the finding.
State Agency: Illinois Governor’s Office of Management and Budget (GOMB) Federal Agency: U.S. Department of Agriculture (USDA), U.S. Department of Justice (DOJ), U.S. Department of Labor (DOL), U.S. Department of Transportation (DOT), U.S. Department of the Treasury (TREAS), U.S. Department of Education (ED), U.S. Department of Health and Human Services (USDHHS) Program Name: Special Supplemental Nutrition Program for Women, Infants and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program, WIOA Cluster, Highway Planning and Construction, Emergency Rental Assistance Program, Homeowner Assistance Fund Program, Coronavirus State and Local Fiscal Recovery Funds, Title I Grants to Local Educational Agencies, Twenty-First Century Community Learning Centers, Supporting Effective Instruction State Grants, Education Stabilization Fund (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families (TANF), Child Support Enforcement, Low-Income Home Energy Assistance Program, Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant, Block Grants for Prevention and Treatment of Substance Abuse ALN and Program Expenditures 10.557 ($168,740,425), 10.558 ($156,353,139), 16.575 ($78,196,419), 17.258/17.259/17.278 ($141,177,677), 20.205 ($1,932,300,419), 21.023 ($179,355,381), 21.026 ($177,107,928), 21.027 ($2,804,581,453), 84.010A ($704,235,726), 84.287 ($77,436,583),84.367A ($76,537,613), 84.425 ($2,227,152,891), 93.323 ($174,636,052), 93.558 ($578,867,422), 93.563 ($131,300,355), 93.568 ($288,503,657), 93.575/93.596 ($783,907,069), 93.667 ($57,147,970), 93.959 ($101,011,200) Award Numbers: Various – see table of award numbers Federal Award Year: Various – see table of award numbers Questioned Costs: None Finding 2023-002: Inadequate Monitoring of Subrecipient Single Audit Reviews Compliance Requirement: Subrecipient Monitoring Condition Found: The State of Illinois did not establish adequate controls to monitor the completion and documentation of the review single audit reports for its subrecipients of the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program (CVA), WIOA Cluster (WIOA), Highway and Planning Construction (Highway), Emergency Rental Assistance Program (ERAP), Homeowner Assistance Fund Program (HAF), Coronavirus State and Local Fiscal Recovery Funds (SLFRF), Twenty-First Century Community Learning Centers (Twenty-First), Title I Grants to Local Education Agencies (Title I), Supporting Effective Instruction State Grants (SEISG), Education Stabilization Funds (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families Cluster (TANF), Child Support Enforcement (CSE), Low-Income Home Energy Assistance Program (LIHEAP), Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant (SSBG), and Block Grants for Prevention and Treatment of Substance Abuse (SAPT) in the State's Grant Accountability and Transparency Act (GATA) Audit Report Review Management System (ARRMS). The State of Illinois established the Grant Accountability Transparency Unit (GATU) to implement the provisions of GATA on a centralized basis. GATU has established standardized reporting requirements for subrecipients of the various Federal programs administered by the State through its various departments. Subrecipients of the State are required to certify whether they expended more than $750,000 in federal awards during the fiscal year and submit their single audit reporting packages to the Federal Audit Clearinghouse (if required). GATU is then responsible for obtaining the single audit reporting package, verifying the report meets the single audit requirements, and assigning, to the applicable state agency, any findings attributable to amounts passed through to the subrecipient(s) by the State and working with program personnel to issue management decisions on findings. The State utilizes a contractor to perform the centralized functions of obtaining the single audit report, verifying the report meets the requirements, and assigning findings to the applicable State agency. During our testing of subrecipient single audit desk review files for our 2023 major programs, we noted instances where single audit desk reviews were still in process and had not been finalized within GATA ARRMS as of the date of our testing (October 7, 2024). One subrecipient in our sample for the WIC program had incomplete single audit reviews for fiscal years 2019 through 2022, despite the fact the State had obtained the single audit report from the Federal Audit Clearinghouse for each of these fiscal years. Upon further review of data contained within GATA ARRMS, we identified 669 single audit reviews were identified as incomplete in GATA ARRMS for grantees who: (1) reported expenditures under fiscal year 2023 major programs, (2) had an audit report with a FAC acceptance date between January 2, 2022 and January 3, 2023 (requiring the report to be reviewed during fiscal year 2023) and (3) were not sanctioned (placed on the Illinois Stop Payment List) by the State for noncompliance with reporting requirements. These 669 reviews were in varying stages of completion with the majority (608 audits) pending documentation supporting the issuance of a final completion letter by the cognizant agency. The remaining 61 audits (9.1%) were pending receipt of documentation, pending a review, or had another error requiring follow-up. These 669 audits included 323 audits (48.3%) with one or more findings potentially requiring a management decision to be issued. We noted the cognizant agencies for the 669 incomplete single audit reviews in GATA ARRMS were as follows: "See Table in the Audit Report". The 669 incomplete single audit reviews in GATA ARRMS pertained to subrecipients of the following major programs: "See Table in the Audit Report". While in many instances there was evidence the State agencies had completed the necessary procedures outside of GATA ARRMS, the purpose of GATA ARRMS is to reduce the duplication of effort across State agencies and to provide a single submission point for the State’s subrecipients. The lack of monitoring controls around this centralized process may result in noncompliance with subrecipient single audit desk review requirements. The State’s subrecipient expenditures under the federal programs for the year ended June 30, 2023 were as follows: "See Table in the Audit Report". Criteria or Requirement: According to 2 CFR 200.332(d), a pass-through entity is required to monitor the activities of subrecipients as necessary to ensure the federal awards are used for authorized purposes in compliance with laws, regulations, and the provisions of contracts or grant agreements and that performance goals are achieved. Further, 2 CFR 200.332(d)(3) and 2 CFR 200.521 state that a pass-through entity is required to issue a management decision on audit findings within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC) and ensure that the subrecipient takes timely and appropriate corrective action on all audit findings. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, 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. Effective internal controls should include implementing procedures to monitor whether single audit reports are reviewed, management decision letters are issued, and single audit desk review files are closed out in GATA ARRMS in a timely manner. Cause: In discussing these conditions with GOMB officials, management stated that the incompleteness of the State’s audit reviews in GATA ARRMS was due to oversight. Possible Asserted Effect: Failure to complete and document reviews of subrecipient single audit reports in GATA ARRMS in a timely manner may result in noncompliance with the State’s obligation as a pass-through entity to appropriately monitor its subrecipients. Repeat Finding: A similar finding was not reported in the prior year audit (Finding Code 2023-002). Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend GOMB establish procedures to monitor the completion and documentation of single audit report reviews in GATA ARRMS to ensure the State complies with its obligation as a pass-through entity. Views of GOMB Officials: GOMB agrees with the finding.
State Agency: Illinois Governor’s Office of Management and Budget (GOMB) Federal Agency: U.S. Department of Agriculture (USDA), U.S. Department of Justice (DOJ), U.S. Department of Labor (DOL), U.S. Department of Transportation (DOT), U.S. Department of the Treasury (TREAS), U.S. Department of Education (ED), U.S. Department of Health and Human Services (USDHHS) Program Name: Special Supplemental Nutrition Program for Women, Infants and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program, WIOA Cluster, Highway Planning and Construction, Emergency Rental Assistance Program, Homeowner Assistance Fund Program, Coronavirus State and Local Fiscal Recovery Funds, Title I Grants to Local Educational Agencies, Twenty-First Century Community Learning Centers, Supporting Effective Instruction State Grants, Education Stabilization Fund (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families (TANF), Child Support Enforcement, Low-Income Home Energy Assistance Program, Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant, Block Grants for Prevention and Treatment of Substance Abuse ALN and Program Expenditures 10.557 ($168,740,425), 10.558 ($156,353,139), 16.575 ($78,196,419), 17.258/17.259/17.278 ($141,177,677), 20.205 ($1,932,300,419), 21.023 ($179,355,381), 21.026 ($177,107,928), 21.027 ($2,804,581,453), 84.010A ($704,235,726), 84.287 ($77,436,583),84.367A ($76,537,613), 84.425 ($2,227,152,891), 93.323 ($174,636,052), 93.558 ($578,867,422), 93.563 ($131,300,355), 93.568 ($288,503,657), 93.575/93.596 ($783,907,069), 93.667 ($57,147,970), 93.959 ($101,011,200) Award Numbers: Various – see table of award numbers Federal Award Year: Various – see table of award numbers Questioned Costs: None Finding 2023-002: Inadequate Monitoring of Subrecipient Single Audit Reviews Compliance Requirement: Subrecipient Monitoring Condition Found: The State of Illinois did not establish adequate controls to monitor the completion and documentation of the review single audit reports for its subrecipients of the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program (CVA), WIOA Cluster (WIOA), Highway and Planning Construction (Highway), Emergency Rental Assistance Program (ERAP), Homeowner Assistance Fund Program (HAF), Coronavirus State and Local Fiscal Recovery Funds (SLFRF), Twenty-First Century Community Learning Centers (Twenty-First), Title I Grants to Local Education Agencies (Title I), Supporting Effective Instruction State Grants (SEISG), Education Stabilization Funds (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families Cluster (TANF), Child Support Enforcement (CSE), Low-Income Home Energy Assistance Program (LIHEAP), Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant (SSBG), and Block Grants for Prevention and Treatment of Substance Abuse (SAPT) in the State's Grant Accountability and Transparency Act (GATA) Audit Report Review Management System (ARRMS). The State of Illinois established the Grant Accountability Transparency Unit (GATU) to implement the provisions of GATA on a centralized basis. GATU has established standardized reporting requirements for subrecipients of the various Federal programs administered by the State through its various departments. Subrecipients of the State are required to certify whether they expended more than $750,000 in federal awards during the fiscal year and submit their single audit reporting packages to the Federal Audit Clearinghouse (if required). GATU is then responsible for obtaining the single audit reporting package, verifying the report meets the single audit requirements, and assigning, to the applicable state agency, any findings attributable to amounts passed through to the subrecipient(s) by the State and working with program personnel to issue management decisions on findings. The State utilizes a contractor to perform the centralized functions of obtaining the single audit report, verifying the report meets the requirements, and assigning findings to the applicable State agency. During our testing of subrecipient single audit desk review files for our 2023 major programs, we noted instances where single audit desk reviews were still in process and had not been finalized within GATA ARRMS as of the date of our testing (October 7, 2024). One subrecipient in our sample for the WIC program had incomplete single audit reviews for fiscal years 2019 through 2022, despite the fact the State had obtained the single audit report from the Federal Audit Clearinghouse for each of these fiscal years. Upon further review of data contained within GATA ARRMS, we identified 669 single audit reviews were identified as incomplete in GATA ARRMS for grantees who: (1) reported expenditures under fiscal year 2023 major programs, (2) had an audit report with a FAC acceptance date between January 2, 2022 and January 3, 2023 (requiring the report to be reviewed during fiscal year 2023) and (3) were not sanctioned (placed on the Illinois Stop Payment List) by the State for noncompliance with reporting requirements. These 669 reviews were in varying stages of completion with the majority (608 audits) pending documentation supporting the issuance of a final completion letter by the cognizant agency. The remaining 61 audits (9.1%) were pending receipt of documentation, pending a review, or had another error requiring follow-up. These 669 audits included 323 audits (48.3%) with one or more findings potentially requiring a management decision to be issued. We noted the cognizant agencies for the 669 incomplete single audit reviews in GATA ARRMS were as follows: "See Table in the Audit Report". The 669 incomplete single audit reviews in GATA ARRMS pertained to subrecipients of the following major programs: "See Table in the Audit Report". While in many instances there was evidence the State agencies had completed the necessary procedures outside of GATA ARRMS, the purpose of GATA ARRMS is to reduce the duplication of effort across State agencies and to provide a single submission point for the State’s subrecipients. The lack of monitoring controls around this centralized process may result in noncompliance with subrecipient single audit desk review requirements. The State’s subrecipient expenditures under the federal programs for the year ended June 30, 2023 were as follows: "See Table in the Audit Report". Criteria or Requirement: According to 2 CFR 200.332(d), a pass-through entity is required to monitor the activities of subrecipients as necessary to ensure the federal awards are used for authorized purposes in compliance with laws, regulations, and the provisions of contracts or grant agreements and that performance goals are achieved. Further, 2 CFR 200.332(d)(3) and 2 CFR 200.521 state that a pass-through entity is required to issue a management decision on audit findings within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC) and ensure that the subrecipient takes timely and appropriate corrective action on all audit findings. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, 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. Effective internal controls should include implementing procedures to monitor whether single audit reports are reviewed, management decision letters are issued, and single audit desk review files are closed out in GATA ARRMS in a timely manner. Cause: In discussing these conditions with GOMB officials, management stated that the incompleteness of the State’s audit reviews in GATA ARRMS was due to oversight. Possible Asserted Effect: Failure to complete and document reviews of subrecipient single audit reports in GATA ARRMS in a timely manner may result in noncompliance with the State’s obligation as a pass-through entity to appropriately monitor its subrecipients. Repeat Finding: A similar finding was not reported in the prior year audit (Finding Code 2023-002). Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend GOMB establish procedures to monitor the completion and documentation of single audit report reviews in GATA ARRMS to ensure the State complies with its obligation as a pass-through entity. Views of GOMB Officials: GOMB agrees with the finding.
State Agency: Illinois Governor’s Office of Management and Budget (GOMB) Federal Agency: U.S. Department of Agriculture (USDA), U.S. Department of Justice (DOJ), U.S. Department of Labor (DOL), U.S. Department of Transportation (DOT), U.S. Department of the Treasury (TREAS), U.S. Department of Education (ED), U.S. Department of Health and Human Services (USDHHS) Program Name: Special Supplemental Nutrition Program for Women, Infants and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program, WIOA Cluster, Highway Planning and Construction, Emergency Rental Assistance Program, Homeowner Assistance Fund Program, Coronavirus State and Local Fiscal Recovery Funds, Title I Grants to Local Educational Agencies, Twenty-First Century Community Learning Centers, Supporting Effective Instruction State Grants, Education Stabilization Fund (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families (TANF), Child Support Enforcement, Low-Income Home Energy Assistance Program, Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant, Block Grants for Prevention and Treatment of Substance Abuse ALN and Program Expenditures 10.557 ($168,740,425), 10.558 ($156,353,139), 16.575 ($78,196,419), 17.258/17.259/17.278 ($141,177,677), 20.205 ($1,932,300,419), 21.023 ($179,355,381), 21.026 ($177,107,928), 21.027 ($2,804,581,453), 84.010A ($704,235,726), 84.287 ($77,436,583),84.367A ($76,537,613), 84.425 ($2,227,152,891), 93.323 ($174,636,052), 93.558 ($578,867,422), 93.563 ($131,300,355), 93.568 ($288,503,657), 93.575/93.596 ($783,907,069), 93.667 ($57,147,970), 93.959 ($101,011,200) Award Numbers: Various – see table of award numbers Federal Award Year: Various – see table of award numbers Questioned Costs: None Finding 2023-002: Inadequate Monitoring of Subrecipient Single Audit Reviews Compliance Requirement: Subrecipient Monitoring Condition Found: The State of Illinois did not establish adequate controls to monitor the completion and documentation of the review single audit reports for its subrecipients of the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program (CVA), WIOA Cluster (WIOA), Highway and Planning Construction (Highway), Emergency Rental Assistance Program (ERAP), Homeowner Assistance Fund Program (HAF), Coronavirus State and Local Fiscal Recovery Funds (SLFRF), Twenty-First Century Community Learning Centers (Twenty-First), Title I Grants to Local Education Agencies (Title I), Supporting Effective Instruction State Grants (SEISG), Education Stabilization Funds (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families Cluster (TANF), Child Support Enforcement (CSE), Low-Income Home Energy Assistance Program (LIHEAP), Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant (SSBG), and Block Grants for Prevention and Treatment of Substance Abuse (SAPT) in the State's Grant Accountability and Transparency Act (GATA) Audit Report Review Management System (ARRMS). The State of Illinois established the Grant Accountability Transparency Unit (GATU) to implement the provisions of GATA on a centralized basis. GATU has established standardized reporting requirements for subrecipients of the various Federal programs administered by the State through its various departments. Subrecipients of the State are required to certify whether they expended more than $750,000 in federal awards during the fiscal year and submit their single audit reporting packages to the Federal Audit Clearinghouse (if required). GATU is then responsible for obtaining the single audit reporting package, verifying the report meets the single audit requirements, and assigning, to the applicable state agency, any findings attributable to amounts passed through to the subrecipient(s) by the State and working with program personnel to issue management decisions on findings. The State utilizes a contractor to perform the centralized functions of obtaining the single audit report, verifying the report meets the requirements, and assigning findings to the applicable State agency. During our testing of subrecipient single audit desk review files for our 2023 major programs, we noted instances where single audit desk reviews were still in process and had not been finalized within GATA ARRMS as of the date of our testing (October 7, 2024). One subrecipient in our sample for the WIC program had incomplete single audit reviews for fiscal years 2019 through 2022, despite the fact the State had obtained the single audit report from the Federal Audit Clearinghouse for each of these fiscal years. Upon further review of data contained within GATA ARRMS, we identified 669 single audit reviews were identified as incomplete in GATA ARRMS for grantees who: (1) reported expenditures under fiscal year 2023 major programs, (2) had an audit report with a FAC acceptance date between January 2, 2022 and January 3, 2023 (requiring the report to be reviewed during fiscal year 2023) and (3) were not sanctioned (placed on the Illinois Stop Payment List) by the State for noncompliance with reporting requirements. These 669 reviews were in varying stages of completion with the majority (608 audits) pending documentation supporting the issuance of a final completion letter by the cognizant agency. The remaining 61 audits (9.1%) were pending receipt of documentation, pending a review, or had another error requiring follow-up. These 669 audits included 323 audits (48.3%) with one or more findings potentially requiring a management decision to be issued. We noted the cognizant agencies for the 669 incomplete single audit reviews in GATA ARRMS were as follows: "See Table in the Audit Report". The 669 incomplete single audit reviews in GATA ARRMS pertained to subrecipients of the following major programs: "See Table in the Audit Report". While in many instances there was evidence the State agencies had completed the necessary procedures outside of GATA ARRMS, the purpose of GATA ARRMS is to reduce the duplication of effort across State agencies and to provide a single submission point for the State’s subrecipients. The lack of monitoring controls around this centralized process may result in noncompliance with subrecipient single audit desk review requirements. The State’s subrecipient expenditures under the federal programs for the year ended June 30, 2023 were as follows: "See Table in the Audit Report". Criteria or Requirement: According to 2 CFR 200.332(d), a pass-through entity is required to monitor the activities of subrecipients as necessary to ensure the federal awards are used for authorized purposes in compliance with laws, regulations, and the provisions of contracts or grant agreements and that performance goals are achieved. Further, 2 CFR 200.332(d)(3) and 2 CFR 200.521 state that a pass-through entity is required to issue a management decision on audit findings within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC) and ensure that the subrecipient takes timely and appropriate corrective action on all audit findings. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, 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. Effective internal controls should include implementing procedures to monitor whether single audit reports are reviewed, management decision letters are issued, and single audit desk review files are closed out in GATA ARRMS in a timely manner. Cause: In discussing these conditions with GOMB officials, management stated that the incompleteness of the State’s audit reviews in GATA ARRMS was due to oversight. Possible Asserted Effect: Failure to complete and document reviews of subrecipient single audit reports in GATA ARRMS in a timely manner may result in noncompliance with the State’s obligation as a pass-through entity to appropriately monitor its subrecipients. Repeat Finding: A similar finding was not reported in the prior year audit (Finding Code 2023-002). Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend GOMB establish procedures to monitor the completion and documentation of single audit report reviews in GATA ARRMS to ensure the State complies with its obligation as a pass-through entity. Views of GOMB Officials: GOMB agrees with the finding.
State Agency: Illinois Governor’s Office of Management and Budget (GOMB) Federal Agency: U.S. Department of Agriculture (USDA), U.S. Department of Justice (DOJ), U.S. Department of Labor (DOL), U.S. Department of Transportation (DOT), U.S. Department of the Treasury (TREAS), U.S. Department of Education (ED), U.S. Department of Health and Human Services (USDHHS) Program Name: Special Supplemental Nutrition Program for Women, Infants and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program, WIOA Cluster, Highway Planning and Construction, Emergency Rental Assistance Program, Homeowner Assistance Fund Program, Coronavirus State and Local Fiscal Recovery Funds, Title I Grants to Local Educational Agencies, Twenty-First Century Community Learning Centers, Supporting Effective Instruction State Grants, Education Stabilization Fund (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families (TANF), Child Support Enforcement, Low-Income Home Energy Assistance Program, Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant, Block Grants for Prevention and Treatment of Substance Abuse ALN and Program Expenditures 10.557 ($168,740,425), 10.558 ($156,353,139), 16.575 ($78,196,419), 17.258/17.259/17.278 ($141,177,677), 20.205 ($1,932,300,419), 21.023 ($179,355,381), 21.026 ($177,107,928), 21.027 ($2,804,581,453), 84.010A ($704,235,726), 84.287 ($77,436,583),84.367A ($76,537,613), 84.425 ($2,227,152,891), 93.323 ($174,636,052), 93.558 ($578,867,422), 93.563 ($131,300,355), 93.568 ($288,503,657), 93.575/93.596 ($783,907,069), 93.667 ($57,147,970), 93.959 ($101,011,200) Award Numbers: Various – see table of award numbers Federal Award Year: Various – see table of award numbers Questioned Costs: None Finding 2023-002: Inadequate Monitoring of Subrecipient Single Audit Reviews Compliance Requirement: Subrecipient Monitoring Condition Found: The State of Illinois did not establish adequate controls to monitor the completion and documentation of the review single audit reports for its subrecipients of the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program (CVA), WIOA Cluster (WIOA), Highway and Planning Construction (Highway), Emergency Rental Assistance Program (ERAP), Homeowner Assistance Fund Program (HAF), Coronavirus State and Local Fiscal Recovery Funds (SLFRF), Twenty-First Century Community Learning Centers (Twenty-First), Title I Grants to Local Education Agencies (Title I), Supporting Effective Instruction State Grants (SEISG), Education Stabilization Funds (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families Cluster (TANF), Child Support Enforcement (CSE), Low-Income Home Energy Assistance Program (LIHEAP), Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant (SSBG), and Block Grants for Prevention and Treatment of Substance Abuse (SAPT) in the State's Grant Accountability and Transparency Act (GATA) Audit Report Review Management System (ARRMS). The State of Illinois established the Grant Accountability Transparency Unit (GATU) to implement the provisions of GATA on a centralized basis. GATU has established standardized reporting requirements for subrecipients of the various Federal programs administered by the State through its various departments. Subrecipients of the State are required to certify whether they expended more than $750,000 in federal awards during the fiscal year and submit their single audit reporting packages to the Federal Audit Clearinghouse (if required). GATU is then responsible for obtaining the single audit reporting package, verifying the report meets the single audit requirements, and assigning, to the applicable state agency, any findings attributable to amounts passed through to the subrecipient(s) by the State and working with program personnel to issue management decisions on findings. The State utilizes a contractor to perform the centralized functions of obtaining the single audit report, verifying the report meets the requirements, and assigning findings to the applicable State agency. During our testing of subrecipient single audit desk review files for our 2023 major programs, we noted instances where single audit desk reviews were still in process and had not been finalized within GATA ARRMS as of the date of our testing (October 7, 2024). One subrecipient in our sample for the WIC program had incomplete single audit reviews for fiscal years 2019 through 2022, despite the fact the State had obtained the single audit report from the Federal Audit Clearinghouse for each of these fiscal years. Upon further review of data contained within GATA ARRMS, we identified 669 single audit reviews were identified as incomplete in GATA ARRMS for grantees who: (1) reported expenditures under fiscal year 2023 major programs, (2) had an audit report with a FAC acceptance date between January 2, 2022 and January 3, 2023 (requiring the report to be reviewed during fiscal year 2023) and (3) were not sanctioned (placed on the Illinois Stop Payment List) by the State for noncompliance with reporting requirements. These 669 reviews were in varying stages of completion with the majority (608 audits) pending documentation supporting the issuance of a final completion letter by the cognizant agency. The remaining 61 audits (9.1%) were pending receipt of documentation, pending a review, or had another error requiring follow-up. These 669 audits included 323 audits (48.3%) with one or more findings potentially requiring a management decision to be issued. We noted the cognizant agencies for the 669 incomplete single audit reviews in GATA ARRMS were as follows: "See Table in the Audit Report". The 669 incomplete single audit reviews in GATA ARRMS pertained to subrecipients of the following major programs: "See Table in the Audit Report". While in many instances there was evidence the State agencies had completed the necessary procedures outside of GATA ARRMS, the purpose of GATA ARRMS is to reduce the duplication of effort across State agencies and to provide a single submission point for the State’s subrecipients. The lack of monitoring controls around this centralized process may result in noncompliance with subrecipient single audit desk review requirements. The State’s subrecipient expenditures under the federal programs for the year ended June 30, 2023 were as follows: "See Table in the Audit Report". Criteria or Requirement: According to 2 CFR 200.332(d), a pass-through entity is required to monitor the activities of subrecipients as necessary to ensure the federal awards are used for authorized purposes in compliance with laws, regulations, and the provisions of contracts or grant agreements and that performance goals are achieved. Further, 2 CFR 200.332(d)(3) and 2 CFR 200.521 state that a pass-through entity is required to issue a management decision on audit findings within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC) and ensure that the subrecipient takes timely and appropriate corrective action on all audit findings. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, 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. Effective internal controls should include implementing procedures to monitor whether single audit reports are reviewed, management decision letters are issued, and single audit desk review files are closed out in GATA ARRMS in a timely manner. Cause: In discussing these conditions with GOMB officials, management stated that the incompleteness of the State’s audit reviews in GATA ARRMS was due to oversight. Possible Asserted Effect: Failure to complete and document reviews of subrecipient single audit reports in GATA ARRMS in a timely manner may result in noncompliance with the State’s obligation as a pass-through entity to appropriately monitor its subrecipients. Repeat Finding: A similar finding was not reported in the prior year audit (Finding Code 2023-002). Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend GOMB establish procedures to monitor the completion and documentation of single audit report reviews in GATA ARRMS to ensure the State complies with its obligation as a pass-through entity. Views of GOMB Officials: GOMB agrees with the finding.
State Agency: Illinois Governor’s Office of Management and Budget (GOMB) Federal Agency: U.S. Department of Agriculture (USDA), U.S. Department of Justice (DOJ), U.S. Department of Labor (DOL), U.S. Department of Transportation (DOT), U.S. Department of the Treasury (TREAS), U.S. Department of Education (ED), U.S. Department of Health and Human Services (USDHHS) Program Name: Special Supplemental Nutrition Program for Women, Infants and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program, WIOA Cluster, Highway Planning and Construction, Emergency Rental Assistance Program, Homeowner Assistance Fund Program, Coronavirus State and Local Fiscal Recovery Funds, Title I Grants to Local Educational Agencies, Twenty-First Century Community Learning Centers, Supporting Effective Instruction State Grants, Education Stabilization Fund (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families (TANF), Child Support Enforcement, Low-Income Home Energy Assistance Program, Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant, Block Grants for Prevention and Treatment of Substance Abuse ALN and Program Expenditures 10.557 ($168,740,425), 10.558 ($156,353,139), 16.575 ($78,196,419), 17.258/17.259/17.278 ($141,177,677), 20.205 ($1,932,300,419), 21.023 ($179,355,381), 21.026 ($177,107,928), 21.027 ($2,804,581,453), 84.010A ($704,235,726), 84.287 ($77,436,583),84.367A ($76,537,613), 84.425 ($2,227,152,891), 93.323 ($174,636,052), 93.558 ($578,867,422), 93.563 ($131,300,355), 93.568 ($288,503,657), 93.575/93.596 ($783,907,069), 93.667 ($57,147,970), 93.959 ($101,011,200) Award Numbers: Various – see table of award numbers Federal Award Year: Various – see table of award numbers Questioned Costs: None Finding 2023-002: Inadequate Monitoring of Subrecipient Single Audit Reviews Compliance Requirement: Subrecipient Monitoring Condition Found: The State of Illinois did not establish adequate controls to monitor the completion and documentation of the review single audit reports for its subrecipients of the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program (CVA), WIOA Cluster (WIOA), Highway and Planning Construction (Highway), Emergency Rental Assistance Program (ERAP), Homeowner Assistance Fund Program (HAF), Coronavirus State and Local Fiscal Recovery Funds (SLFRF), Twenty-First Century Community Learning Centers (Twenty-First), Title I Grants to Local Education Agencies (Title I), Supporting Effective Instruction State Grants (SEISG), Education Stabilization Funds (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families Cluster (TANF), Child Support Enforcement (CSE), Low-Income Home Energy Assistance Program (LIHEAP), Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant (SSBG), and Block Grants for Prevention and Treatment of Substance Abuse (SAPT) in the State's Grant Accountability and Transparency Act (GATA) Audit Report Review Management System (ARRMS). The State of Illinois established the Grant Accountability Transparency Unit (GATU) to implement the provisions of GATA on a centralized basis. GATU has established standardized reporting requirements for subrecipients of the various Federal programs administered by the State through its various departments. Subrecipients of the State are required to certify whether they expended more than $750,000 in federal awards during the fiscal year and submit their single audit reporting packages to the Federal Audit Clearinghouse (if required). GATU is then responsible for obtaining the single audit reporting package, verifying the report meets the single audit requirements, and assigning, to the applicable state agency, any findings attributable to amounts passed through to the subrecipient(s) by the State and working with program personnel to issue management decisions on findings. The State utilizes a contractor to perform the centralized functions of obtaining the single audit report, verifying the report meets the requirements, and assigning findings to the applicable State agency. During our testing of subrecipient single audit desk review files for our 2023 major programs, we noted instances where single audit desk reviews were still in process and had not been finalized within GATA ARRMS as of the date of our testing (October 7, 2024). One subrecipient in our sample for the WIC program had incomplete single audit reviews for fiscal years 2019 through 2022, despite the fact the State had obtained the single audit report from the Federal Audit Clearinghouse for each of these fiscal years. Upon further review of data contained within GATA ARRMS, we identified 669 single audit reviews were identified as incomplete in GATA ARRMS for grantees who: (1) reported expenditures under fiscal year 2023 major programs, (2) had an audit report with a FAC acceptance date between January 2, 2022 and January 3, 2023 (requiring the report to be reviewed during fiscal year 2023) and (3) were not sanctioned (placed on the Illinois Stop Payment List) by the State for noncompliance with reporting requirements. These 669 reviews were in varying stages of completion with the majority (608 audits) pending documentation supporting the issuance of a final completion letter by the cognizant agency. The remaining 61 audits (9.1%) were pending receipt of documentation, pending a review, or had another error requiring follow-up. These 669 audits included 323 audits (48.3%) with one or more findings potentially requiring a management decision to be issued. We noted the cognizant agencies for the 669 incomplete single audit reviews in GATA ARRMS were as follows: "See Table in the Audit Report". The 669 incomplete single audit reviews in GATA ARRMS pertained to subrecipients of the following major programs: "See Table in the Audit Report". While in many instances there was evidence the State agencies had completed the necessary procedures outside of GATA ARRMS, the purpose of GATA ARRMS is to reduce the duplication of effort across State agencies and to provide a single submission point for the State’s subrecipients. The lack of monitoring controls around this centralized process may result in noncompliance with subrecipient single audit desk review requirements. The State’s subrecipient expenditures under the federal programs for the year ended June 30, 2023 were as follows: "See Table in the Audit Report". Criteria or Requirement: According to 2 CFR 200.332(d), a pass-through entity is required to monitor the activities of subrecipients as necessary to ensure the federal awards are used for authorized purposes in compliance with laws, regulations, and the provisions of contracts or grant agreements and that performance goals are achieved. Further, 2 CFR 200.332(d)(3) and 2 CFR 200.521 state that a pass-through entity is required to issue a management decision on audit findings within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC) and ensure that the subrecipient takes timely and appropriate corrective action on all audit findings. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, 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. Effective internal controls should include implementing procedures to monitor whether single audit reports are reviewed, management decision letters are issued, and single audit desk review files are closed out in GATA ARRMS in a timely manner. Cause: In discussing these conditions with GOMB officials, management stated that the incompleteness of the State’s audit reviews in GATA ARRMS was due to oversight. Possible Asserted Effect: Failure to complete and document reviews of subrecipient single audit reports in GATA ARRMS in a timely manner may result in noncompliance with the State’s obligation as a pass-through entity to appropriately monitor its subrecipients. Repeat Finding: A similar finding was not reported in the prior year audit (Finding Code 2023-002). Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend GOMB establish procedures to monitor the completion and documentation of single audit report reviews in GATA ARRMS to ensure the State complies with its obligation as a pass-through entity. Views of GOMB Officials: GOMB agrees with the finding.
State Agency: Illinois Governor’s Office of Management and Budget (GOMB) Federal Agency: U.S. Department of Agriculture (USDA), U.S. Department of Justice (DOJ), U.S. Department of Labor (DOL), U.S. Department of Transportation (DOT), U.S. Department of the Treasury (TREAS), U.S. Department of Education (ED), U.S. Department of Health and Human Services (USDHHS) Program Name: Special Supplemental Nutrition Program for Women, Infants and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program, WIOA Cluster, Highway Planning and Construction, Emergency Rental Assistance Program, Homeowner Assistance Fund Program, Coronavirus State and Local Fiscal Recovery Funds, Title I Grants to Local Educational Agencies, Twenty-First Century Community Learning Centers, Supporting Effective Instruction State Grants, Education Stabilization Fund (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families (TANF), Child Support Enforcement, Low-Income Home Energy Assistance Program, Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant, Block Grants for Prevention and Treatment of Substance Abuse ALN and Program Expenditures 10.557 ($168,740,425), 10.558 ($156,353,139), 16.575 ($78,196,419), 17.258/17.259/17.278 ($141,177,677), 20.205 ($1,932,300,419), 21.023 ($179,355,381), 21.026 ($177,107,928), 21.027 ($2,804,581,453), 84.010A ($704,235,726), 84.287 ($77,436,583),84.367A ($76,537,613), 84.425 ($2,227,152,891), 93.323 ($174,636,052), 93.558 ($578,867,422), 93.563 ($131,300,355), 93.568 ($288,503,657), 93.575/93.596 ($783,907,069), 93.667 ($57,147,970), 93.959 ($101,011,200) Award Numbers: Various – see table of award numbers Federal Award Year: Various – see table of award numbers Questioned Costs: None Finding 2023-002: Inadequate Monitoring of Subrecipient Single Audit Reviews Compliance Requirement: Subrecipient Monitoring Condition Found: The State of Illinois did not establish adequate controls to monitor the completion and documentation of the review single audit reports for its subrecipients of the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program (CVA), WIOA Cluster (WIOA), Highway and Planning Construction (Highway), Emergency Rental Assistance Program (ERAP), Homeowner Assistance Fund Program (HAF), Coronavirus State and Local Fiscal Recovery Funds (SLFRF), Twenty-First Century Community Learning Centers (Twenty-First), Title I Grants to Local Education Agencies (Title I), Supporting Effective Instruction State Grants (SEISG), Education Stabilization Funds (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families Cluster (TANF), Child Support Enforcement (CSE), Low-Income Home Energy Assistance Program (LIHEAP), Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant (SSBG), and Block Grants for Prevention and Treatment of Substance Abuse (SAPT) in the State's Grant Accountability and Transparency Act (GATA) Audit Report Review Management System (ARRMS). The State of Illinois established the Grant Accountability Transparency Unit (GATU) to implement the provisions of GATA on a centralized basis. GATU has established standardized reporting requirements for subrecipients of the various Federal programs administered by the State through its various departments. Subrecipients of the State are required to certify whether they expended more than $750,000 in federal awards during the fiscal year and submit their single audit reporting packages to the Federal Audit Clearinghouse (if required). GATU is then responsible for obtaining the single audit reporting package, verifying the report meets the single audit requirements, and assigning, to the applicable state agency, any findings attributable to amounts passed through to the subrecipient(s) by the State and working with program personnel to issue management decisions on findings. The State utilizes a contractor to perform the centralized functions of obtaining the single audit report, verifying the report meets the requirements, and assigning findings to the applicable State agency. During our testing of subrecipient single audit desk review files for our 2023 major programs, we noted instances where single audit desk reviews were still in process and had not been finalized within GATA ARRMS as of the date of our testing (October 7, 2024). One subrecipient in our sample for the WIC program had incomplete single audit reviews for fiscal years 2019 through 2022, despite the fact the State had obtained the single audit report from the Federal Audit Clearinghouse for each of these fiscal years. Upon further review of data contained within GATA ARRMS, we identified 669 single audit reviews were identified as incomplete in GATA ARRMS for grantees who: (1) reported expenditures under fiscal year 2023 major programs, (2) had an audit report with a FAC acceptance date between January 2, 2022 and January 3, 2023 (requiring the report to be reviewed during fiscal year 2023) and (3) were not sanctioned (placed on the Illinois Stop Payment List) by the State for noncompliance with reporting requirements. These 669 reviews were in varying stages of completion with the majority (608 audits) pending documentation supporting the issuance of a final completion letter by the cognizant agency. The remaining 61 audits (9.1%) were pending receipt of documentation, pending a review, or had another error requiring follow-up. These 669 audits included 323 audits (48.3%) with one or more findings potentially requiring a management decision to be issued. We noted the cognizant agencies for the 669 incomplete single audit reviews in GATA ARRMS were as follows: "See Table in the Audit Report". The 669 incomplete single audit reviews in GATA ARRMS pertained to subrecipients of the following major programs: "See Table in the Audit Report". While in many instances there was evidence the State agencies had completed the necessary procedures outside of GATA ARRMS, the purpose of GATA ARRMS is to reduce the duplication of effort across State agencies and to provide a single submission point for the State’s subrecipients. The lack of monitoring controls around this centralized process may result in noncompliance with subrecipient single audit desk review requirements. The State’s subrecipient expenditures under the federal programs for the year ended June 30, 2023 were as follows: "See Table in the Audit Report". Criteria or Requirement: According to 2 CFR 200.332(d), a pass-through entity is required to monitor the activities of subrecipients as necessary to ensure the federal awards are used for authorized purposes in compliance with laws, regulations, and the provisions of contracts or grant agreements and that performance goals are achieved. Further, 2 CFR 200.332(d)(3) and 2 CFR 200.521 state that a pass-through entity is required to issue a management decision on audit findings within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC) and ensure that the subrecipient takes timely and appropriate corrective action on all audit findings. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, 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. Effective internal controls should include implementing procedures to monitor whether single audit reports are reviewed, management decision letters are issued, and single audit desk review files are closed out in GATA ARRMS in a timely manner. Cause: In discussing these conditions with GOMB officials, management stated that the incompleteness of the State’s audit reviews in GATA ARRMS was due to oversight. Possible Asserted Effect: Failure to complete and document reviews of subrecipient single audit reports in GATA ARRMS in a timely manner may result in noncompliance with the State’s obligation as a pass-through entity to appropriately monitor its subrecipients. Repeat Finding: A similar finding was not reported in the prior year audit (Finding Code 2023-002). Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend GOMB establish procedures to monitor the completion and documentation of single audit report reviews in GATA ARRMS to ensure the State complies with its obligation as a pass-through entity. Views of GOMB Officials: GOMB agrees with the finding.
State Agency: Illinois Governor’s Office of Management and Budget (GOMB) Federal Agency: U.S. Department of Agriculture (USDA), U.S. Department of Justice (DOJ), U.S. Department of Labor (DOL), U.S. Department of Transportation (DOT), U.S. Department of the Treasury (TREAS), U.S. Department of Education (ED), U.S. Department of Health and Human Services (USDHHS) Program Name: Special Supplemental Nutrition Program for Women, Infants and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program, WIOA Cluster, Highway Planning and Construction, Emergency Rental Assistance Program, Homeowner Assistance Fund Program, Coronavirus State and Local Fiscal Recovery Funds, Title I Grants to Local Educational Agencies, Twenty-First Century Community Learning Centers, Supporting Effective Instruction State Grants, Education Stabilization Fund (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families (TANF), Child Support Enforcement, Low-Income Home Energy Assistance Program, Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant, Block Grants for Prevention and Treatment of Substance Abuse ALN and Program Expenditures 10.557 ($168,740,425), 10.558 ($156,353,139), 16.575 ($78,196,419), 17.258/17.259/17.278 ($141,177,677), 20.205 ($1,932,300,419), 21.023 ($179,355,381), 21.026 ($177,107,928), 21.027 ($2,804,581,453), 84.010A ($704,235,726), 84.287 ($77,436,583),84.367A ($76,537,613), 84.425 ($2,227,152,891), 93.323 ($174,636,052), 93.558 ($578,867,422), 93.563 ($131,300,355), 93.568 ($288,503,657), 93.575/93.596 ($783,907,069), 93.667 ($57,147,970), 93.959 ($101,011,200) Award Numbers: Various – see table of award numbers Federal Award Year: Various – see table of award numbers Questioned Costs: None Finding 2023-002: Inadequate Monitoring of Subrecipient Single Audit Reviews Compliance Requirement: Subrecipient Monitoring Condition Found: The State of Illinois did not establish adequate controls to monitor the completion and documentation of the review single audit reports for its subrecipients of the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program (CVA), WIOA Cluster (WIOA), Highway and Planning Construction (Highway), Emergency Rental Assistance Program (ERAP), Homeowner Assistance Fund Program (HAF), Coronavirus State and Local Fiscal Recovery Funds (SLFRF), Twenty-First Century Community Learning Centers (Twenty-First), Title I Grants to Local Education Agencies (Title I), Supporting Effective Instruction State Grants (SEISG), Education Stabilization Funds (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families Cluster (TANF), Child Support Enforcement (CSE), Low-Income Home Energy Assistance Program (LIHEAP), Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant (SSBG), and Block Grants for Prevention and Treatment of Substance Abuse (SAPT) in the State's Grant Accountability and Transparency Act (GATA) Audit Report Review Management System (ARRMS). The State of Illinois established the Grant Accountability Transparency Unit (GATU) to implement the provisions of GATA on a centralized basis. GATU has established standardized reporting requirements for subrecipients of the various Federal programs administered by the State through its various departments. Subrecipients of the State are required to certify whether they expended more than $750,000 in federal awards during the fiscal year and submit their single audit reporting packages to the Federal Audit Clearinghouse (if required). GATU is then responsible for obtaining the single audit reporting package, verifying the report meets the single audit requirements, and assigning, to the applicable state agency, any findings attributable to amounts passed through to the subrecipient(s) by the State and working with program personnel to issue management decisions on findings. The State utilizes a contractor to perform the centralized functions of obtaining the single audit report, verifying the report meets the requirements, and assigning findings to the applicable State agency. During our testing of subrecipient single audit desk review files for our 2023 major programs, we noted instances where single audit desk reviews were still in process and had not been finalized within GATA ARRMS as of the date of our testing (October 7, 2024). One subrecipient in our sample for the WIC program had incomplete single audit reviews for fiscal years 2019 through 2022, despite the fact the State had obtained the single audit report from the Federal Audit Clearinghouse for each of these fiscal years. Upon further review of data contained within GATA ARRMS, we identified 669 single audit reviews were identified as incomplete in GATA ARRMS for grantees who: (1) reported expenditures under fiscal year 2023 major programs, (2) had an audit report with a FAC acceptance date between January 2, 2022 and January 3, 2023 (requiring the report to be reviewed during fiscal year 2023) and (3) were not sanctioned (placed on the Illinois Stop Payment List) by the State for noncompliance with reporting requirements. These 669 reviews were in varying stages of completion with the majority (608 audits) pending documentation supporting the issuance of a final completion letter by the cognizant agency. The remaining 61 audits (9.1%) were pending receipt of documentation, pending a review, or had another error requiring follow-up. These 669 audits included 323 audits (48.3%) with one or more findings potentially requiring a management decision to be issued. We noted the cognizant agencies for the 669 incomplete single audit reviews in GATA ARRMS were as follows: "See Table in the Audit Report". The 669 incomplete single audit reviews in GATA ARRMS pertained to subrecipients of the following major programs: "See Table in the Audit Report". While in many instances there was evidence the State agencies had completed the necessary procedures outside of GATA ARRMS, the purpose of GATA ARRMS is to reduce the duplication of effort across State agencies and to provide a single submission point for the State’s subrecipients. The lack of monitoring controls around this centralized process may result in noncompliance with subrecipient single audit desk review requirements. The State’s subrecipient expenditures under the federal programs for the year ended June 30, 2023 were as follows: "See Table in the Audit Report". Criteria or Requirement: According to 2 CFR 200.332(d), a pass-through entity is required to monitor the activities of subrecipients as necessary to ensure the federal awards are used for authorized purposes in compliance with laws, regulations, and the provisions of contracts or grant agreements and that performance goals are achieved. Further, 2 CFR 200.332(d)(3) and 2 CFR 200.521 state that a pass-through entity is required to issue a management decision on audit findings within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC) and ensure that the subrecipient takes timely and appropriate corrective action on all audit findings. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, 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. Effective internal controls should include implementing procedures to monitor whether single audit reports are reviewed, management decision letters are issued, and single audit desk review files are closed out in GATA ARRMS in a timely manner. Cause: In discussing these conditions with GOMB officials, management stated that the incompleteness of the State’s audit reviews in GATA ARRMS was due to oversight. Possible Asserted Effect: Failure to complete and document reviews of subrecipient single audit reports in GATA ARRMS in a timely manner may result in noncompliance with the State’s obligation as a pass-through entity to appropriately monitor its subrecipients. Repeat Finding: A similar finding was not reported in the prior year audit (Finding Code 2023-002). Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend GOMB establish procedures to monitor the completion and documentation of single audit report reviews in GATA ARRMS to ensure the State complies with its obligation as a pass-through entity. Views of GOMB Officials: GOMB agrees with the finding.
State Agency: Illinois Governor’s Office of Management and Budget (GOMB) Federal Agency: U.S. Department of Agriculture (USDA), U.S. Department of Justice (DOJ), U.S. Department of Labor (DOL), U.S. Department of Transportation (DOT), U.S. Department of the Treasury (TREAS), U.S. Department of Education (ED), U.S. Department of Health and Human Services (USDHHS) Program Name: Special Supplemental Nutrition Program for Women, Infants and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program, WIOA Cluster, Highway Planning and Construction, Emergency Rental Assistance Program, Homeowner Assistance Fund Program, Coronavirus State and Local Fiscal Recovery Funds, Title I Grants to Local Educational Agencies, Twenty-First Century Community Learning Centers, Supporting Effective Instruction State Grants, Education Stabilization Fund (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families (TANF), Child Support Enforcement, Low-Income Home Energy Assistance Program, Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant, Block Grants for Prevention and Treatment of Substance Abuse ALN and Program Expenditures 10.557 ($168,740,425), 10.558 ($156,353,139), 16.575 ($78,196,419), 17.258/17.259/17.278 ($141,177,677), 20.205 ($1,932,300,419), 21.023 ($179,355,381), 21.026 ($177,107,928), 21.027 ($2,804,581,453), 84.010A ($704,235,726), 84.287 ($77,436,583),84.367A ($76,537,613), 84.425 ($2,227,152,891), 93.323 ($174,636,052), 93.558 ($578,867,422), 93.563 ($131,300,355), 93.568 ($288,503,657), 93.575/93.596 ($783,907,069), 93.667 ($57,147,970), 93.959 ($101,011,200) Award Numbers: Various – see table of award numbers Federal Award Year: Various – see table of award numbers Questioned Costs: None Finding 2023-002: Inadequate Monitoring of Subrecipient Single Audit Reviews Compliance Requirement: Subrecipient Monitoring Condition Found: The State of Illinois did not establish adequate controls to monitor the completion and documentation of the review single audit reports for its subrecipients of the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program (CVA), WIOA Cluster (WIOA), Highway and Planning Construction (Highway), Emergency Rental Assistance Program (ERAP), Homeowner Assistance Fund Program (HAF), Coronavirus State and Local Fiscal Recovery Funds (SLFRF), Twenty-First Century Community Learning Centers (Twenty-First), Title I Grants to Local Education Agencies (Title I), Supporting Effective Instruction State Grants (SEISG), Education Stabilization Funds (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families Cluster (TANF), Child Support Enforcement (CSE), Low-Income Home Energy Assistance Program (LIHEAP), Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant (SSBG), and Block Grants for Prevention and Treatment of Substance Abuse (SAPT) in the State's Grant Accountability and Transparency Act (GATA) Audit Report Review Management System (ARRMS). The State of Illinois established the Grant Accountability Transparency Unit (GATU) to implement the provisions of GATA on a centralized basis. GATU has established standardized reporting requirements for subrecipients of the various Federal programs administered by the State through its various departments. Subrecipients of the State are required to certify whether they expended more than $750,000 in federal awards during the fiscal year and submit their single audit reporting packages to the Federal Audit Clearinghouse (if required). GATU is then responsible for obtaining the single audit reporting package, verifying the report meets the single audit requirements, and assigning, to the applicable state agency, any findings attributable to amounts passed through to the subrecipient(s) by the State and working with program personnel to issue management decisions on findings. The State utilizes a contractor to perform the centralized functions of obtaining the single audit report, verifying the report meets the requirements, and assigning findings to the applicable State agency. During our testing of subrecipient single audit desk review files for our 2023 major programs, we noted instances where single audit desk reviews were still in process and had not been finalized within GATA ARRMS as of the date of our testing (October 7, 2024). One subrecipient in our sample for the WIC program had incomplete single audit reviews for fiscal years 2019 through 2022, despite the fact the State had obtained the single audit report from the Federal Audit Clearinghouse for each of these fiscal years. Upon further review of data contained within GATA ARRMS, we identified 669 single audit reviews were identified as incomplete in GATA ARRMS for grantees who: (1) reported expenditures under fiscal year 2023 major programs, (2) had an audit report with a FAC acceptance date between January 2, 2022 and January 3, 2023 (requiring the report to be reviewed during fiscal year 2023) and (3) were not sanctioned (placed on the Illinois Stop Payment List) by the State for noncompliance with reporting requirements. These 669 reviews were in varying stages of completion with the majority (608 audits) pending documentation supporting the issuance of a final completion letter by the cognizant agency. The remaining 61 audits (9.1%) were pending receipt of documentation, pending a review, or had another error requiring follow-up. These 669 audits included 323 audits (48.3%) with one or more findings potentially requiring a management decision to be issued. We noted the cognizant agencies for the 669 incomplete single audit reviews in GATA ARRMS were as follows: "See Table in the Audit Report". The 669 incomplete single audit reviews in GATA ARRMS pertained to subrecipients of the following major programs: "See Table in the Audit Report". While in many instances there was evidence the State agencies had completed the necessary procedures outside of GATA ARRMS, the purpose of GATA ARRMS is to reduce the duplication of effort across State agencies and to provide a single submission point for the State’s subrecipients. The lack of monitoring controls around this centralized process may result in noncompliance with subrecipient single audit desk review requirements. The State’s subrecipient expenditures under the federal programs for the year ended June 30, 2023 were as follows: "See Table in the Audit Report". Criteria or Requirement: According to 2 CFR 200.332(d), a pass-through entity is required to monitor the activities of subrecipients as necessary to ensure the federal awards are used for authorized purposes in compliance with laws, regulations, and the provisions of contracts or grant agreements and that performance goals are achieved. Further, 2 CFR 200.332(d)(3) and 2 CFR 200.521 state that a pass-through entity is required to issue a management decision on audit findings within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC) and ensure that the subrecipient takes timely and appropriate corrective action on all audit findings. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, 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. Effective internal controls should include implementing procedures to monitor whether single audit reports are reviewed, management decision letters are issued, and single audit desk review files are closed out in GATA ARRMS in a timely manner. Cause: In discussing these conditions with GOMB officials, management stated that the incompleteness of the State’s audit reviews in GATA ARRMS was due to oversight. Possible Asserted Effect: Failure to complete and document reviews of subrecipient single audit reports in GATA ARRMS in a timely manner may result in noncompliance with the State’s obligation as a pass-through entity to appropriately monitor its subrecipients. Repeat Finding: A similar finding was not reported in the prior year audit (Finding Code 2023-002). Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend GOMB establish procedures to monitor the completion and documentation of single audit report reviews in GATA ARRMS to ensure the State complies with its obligation as a pass-through entity. Views of GOMB Officials: GOMB agrees with the finding.
State Agency: Illinois Governor’s Office of Management and Budget (GOMB) Federal Agency: U.S. Department of Agriculture (USDA), U.S. Department of Justice (DOJ), U.S. Department of Labor (DOL), U.S. Department of Transportation (DOT), U.S. Department of the Treasury (TREAS), U.S. Department of Education (ED), U.S. Department of Health and Human Services (USDHHS) Program Name: Special Supplemental Nutrition Program for Women, Infants and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program, WIOA Cluster, Highway Planning and Construction, Emergency Rental Assistance Program, Homeowner Assistance Fund Program, Coronavirus State and Local Fiscal Recovery Funds, Title I Grants to Local Educational Agencies, Twenty-First Century Community Learning Centers, Supporting Effective Instruction State Grants, Education Stabilization Fund (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families (TANF), Child Support Enforcement, Low-Income Home Energy Assistance Program, Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant, Block Grants for Prevention and Treatment of Substance Abuse ALN and Program Expenditures 10.557 ($168,740,425), 10.558 ($156,353,139), 16.575 ($78,196,419), 17.258/17.259/17.278 ($141,177,677), 20.205 ($1,932,300,419), 21.023 ($179,355,381), 21.026 ($177,107,928), 21.027 ($2,804,581,453), 84.010A ($704,235,726), 84.287 ($77,436,583),84.367A ($76,537,613), 84.425 ($2,227,152,891), 93.323 ($174,636,052), 93.558 ($578,867,422), 93.563 ($131,300,355), 93.568 ($288,503,657), 93.575/93.596 ($783,907,069), 93.667 ($57,147,970), 93.959 ($101,011,200) Award Numbers: Various – see table of award numbers Federal Award Year: Various – see table of award numbers Questioned Costs: None Finding 2023-002: Inadequate Monitoring of Subrecipient Single Audit Reviews Compliance Requirement: Subrecipient Monitoring Condition Found: The State of Illinois did not establish adequate controls to monitor the completion and documentation of the review single audit reports for its subrecipients of the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program (CVA), WIOA Cluster (WIOA), Highway and Planning Construction (Highway), Emergency Rental Assistance Program (ERAP), Homeowner Assistance Fund Program (HAF), Coronavirus State and Local Fiscal Recovery Funds (SLFRF), Twenty-First Century Community Learning Centers (Twenty-First), Title I Grants to Local Education Agencies (Title I), Supporting Effective Instruction State Grants (SEISG), Education Stabilization Funds (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families Cluster (TANF), Child Support Enforcement (CSE), Low-Income Home Energy Assistance Program (LIHEAP), Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant (SSBG), and Block Grants for Prevention and Treatment of Substance Abuse (SAPT) in the State's Grant Accountability and Transparency Act (GATA) Audit Report Review Management System (ARRMS). The State of Illinois established the Grant Accountability Transparency Unit (GATU) to implement the provisions of GATA on a centralized basis. GATU has established standardized reporting requirements for subrecipients of the various Federal programs administered by the State through its various departments. Subrecipients of the State are required to certify whether they expended more than $750,000 in federal awards during the fiscal year and submit their single audit reporting packages to the Federal Audit Clearinghouse (if required). GATU is then responsible for obtaining the single audit reporting package, verifying the report meets the single audit requirements, and assigning, to the applicable state agency, any findings attributable to amounts passed through to the subrecipient(s) by the State and working with program personnel to issue management decisions on findings. The State utilizes a contractor to perform the centralized functions of obtaining the single audit report, verifying the report meets the requirements, and assigning findings to the applicable State agency. During our testing of subrecipient single audit desk review files for our 2023 major programs, we noted instances where single audit desk reviews were still in process and had not been finalized within GATA ARRMS as of the date of our testing (October 7, 2024). One subrecipient in our sample for the WIC program had incomplete single audit reviews for fiscal years 2019 through 2022, despite the fact the State had obtained the single audit report from the Federal Audit Clearinghouse for each of these fiscal years. Upon further review of data contained within GATA ARRMS, we identified 669 single audit reviews were identified as incomplete in GATA ARRMS for grantees who: (1) reported expenditures under fiscal year 2023 major programs, (2) had an audit report with a FAC acceptance date between January 2, 2022 and January 3, 2023 (requiring the report to be reviewed during fiscal year 2023) and (3) were not sanctioned (placed on the Illinois Stop Payment List) by the State for noncompliance with reporting requirements. These 669 reviews were in varying stages of completion with the majority (608 audits) pending documentation supporting the issuance of a final completion letter by the cognizant agency. The remaining 61 audits (9.1%) were pending receipt of documentation, pending a review, or had another error requiring follow-up. These 669 audits included 323 audits (48.3%) with one or more findings potentially requiring a management decision to be issued. We noted the cognizant agencies for the 669 incomplete single audit reviews in GATA ARRMS were as follows: "See Table in the Audit Report". The 669 incomplete single audit reviews in GATA ARRMS pertained to subrecipients of the following major programs: "See Table in the Audit Report". While in many instances there was evidence the State agencies had completed the necessary procedures outside of GATA ARRMS, the purpose of GATA ARRMS is to reduce the duplication of effort across State agencies and to provide a single submission point for the State’s subrecipients. The lack of monitoring controls around this centralized process may result in noncompliance with subrecipient single audit desk review requirements. The State’s subrecipient expenditures under the federal programs for the year ended June 30, 2023 were as follows: "See Table in the Audit Report". Criteria or Requirement: According to 2 CFR 200.332(d), a pass-through entity is required to monitor the activities of subrecipients as necessary to ensure the federal awards are used for authorized purposes in compliance with laws, regulations, and the provisions of contracts or grant agreements and that performance goals are achieved. Further, 2 CFR 200.332(d)(3) and 2 CFR 200.521 state that a pass-through entity is required to issue a management decision on audit findings within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC) and ensure that the subrecipient takes timely and appropriate corrective action on all audit findings. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, 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. Effective internal controls should include implementing procedures to monitor whether single audit reports are reviewed, management decision letters are issued, and single audit desk review files are closed out in GATA ARRMS in a timely manner. Cause: In discussing these conditions with GOMB officials, management stated that the incompleteness of the State’s audit reviews in GATA ARRMS was due to oversight. Possible Asserted Effect: Failure to complete and document reviews of subrecipient single audit reports in GATA ARRMS in a timely manner may result in noncompliance with the State’s obligation as a pass-through entity to appropriately monitor its subrecipients. Repeat Finding: A similar finding was not reported in the prior year audit (Finding Code 2023-002). Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend GOMB establish procedures to monitor the completion and documentation of single audit report reviews in GATA ARRMS to ensure the State complies with its obligation as a pass-through entity. Views of GOMB Officials: GOMB agrees with the finding.