Finding Text
2022-002 Preparation of Schedule of Expenditures and Federal Awards (?SEFA?) and timelysubmission to Federal Clearing HouseSignificant deficiency in internal control over complianceFederal Program(s) ? All programsFederal Award Year ? June 30, 2022Criteria:2 CFR 200.302(b)(1) states that the nonfederal entity must identify in its accounts all federal awardsreceived and expended, as well as the federal programs under which they were received. Federalprogram and award identification must include, as applicable, the assistance listing title and number,the federal award identification number and year, the name of the federal agency, and the name of thepass-through entity, if any. This information enables the auditee to reconcile amounts presented in thefinancial statements to related amounts in the schedule of expenditures of federal awards. Managementis responsible for the preparation of the SEFA and timely submission of the audited package to theFederal Clearing House.Condition/context:GRYC maintains grant agreements with various government funding pass-through entities. WhileGRYC may not always be subject to the Uniform Guidance report due to not meeting the fundingthreshold, in fiscal year 2022, GRYC exceeded the annual minimal reporting requirement of $750,000.GRYC?s Uniform Guidance audit package was due for submission to the Federal Clearing House byMarch 31, 2023. However, GRYC was unable to effectively determine funding from federal programsthat were subject to Uniform Guidance and as a result, it did not submit the audited package to theFederal Clearing House on time.Cause:Prior to fiscal 2022, GRYC was not subject to the Uniform Guidance audit. In addition, all GRYC?sfederal funding is considered pass-through. As a result, GRYC was under the impression that none oftheir funding was considered federal funding subject to Uniform Guidance. Consequently, GRYC wasunable to sufficiently generate information on all federal funding received during fiscal year 2022 andas a result there was insufficient information available, which led to a delay in the audit process andfiling with the Federal Clearing House.Effect:GRYC maintains its grant documentation internally, however, GRYC did not consider several grantsas being subject to Uniform Guidance in preparation of their SEFA. GRYC did not meet the March31st, 2023, deadline for Federal Clearing House filing.Auditors? Recommendation:We recommend that GRYC develop policies and procedures to ensure compliance with the UniformGuidance reporting requirements that includes proper and timely preparation of SEFA and the timelyfiling of the audit package to the Federal Clearing House. We recommend frequent communicationbetween GRYC and pass-through agencies (funding sources) to help identify federal programs. Inaddition, we recommend GRYC provides more training to grant management staff to both enhancethe skill in identifying pass through programs and ensure the accuracy and completeness of the SEFA.The above recommendation can also be achieved by reviewing all contracts thoroughly and lookingfor provisions that state whether the contracts are federal or state funded. Similarly, if a contract hasan Assistance Listing Number (?ALN?), this could potentially indicate that such grant is federallyfunded. GRYC should also develop better procedures to track all revenues and expenditures over thenext fiscal year to determine whether it exceeded the $750,000 threshold and will be subject to anUniform Guidance audit.Managements Response:GRYC acknowledges and agrees with the finding and is in process of reviewing and analyzing allcontracts and amendments to ensure that the SEFA includes all federally awarded programs. GRYCwill start implementing this recommendation during the year ended June 30, 2023, and plans to filethe 2023 Uniform Guidance report timely.