Finding Text
Condition: An effective internal control system was not in place to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirements.
Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards 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)."
Cause: CICOA's management did not maintain a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: Several required reports were not submitted timely to the Indiana Family and Social Services Administration in accordance with its grant awards. The following reports were identified as not being completed and submitted timely:
• One of a sample of two submissions examined for client/unit data were not entered in CaMSS system by the end of the month following the month of service. The March 2023 submission was not fully completed until June 9, 2023. It should have been submitted by April 30, 2023.
• The expenditure data is to be entered within 75 days of the quarter. From a sample size of two of four, both the December 31, 2022 and the March 31, 2023 were not entered until August 4, 2023, which exceeded the 75 days requirement.
• The non-federal expenditures report is to be submitted within 15 days after the end of the quarter. From a sample of two of four, the information for the quarter ended December 31, 2022 was not submitted until January 23, 2023 and the submission date for the quarter ended March 31, 2023 could not be documented.
Recommendation: We recommend that CICOA establish controls to ensure proper monitoring exists to ensure all reporting requirements for the grants are prepared and submitted timely.
Views of Responsible Officials and Planned Corrective Actions: Management recognizes its compliance requirements for maintaining and implementing sound controls over financial reporting and the potential non-compliance impacts of a lack of such control environment. Leadership is currently considering options for adequate oversight and review. Until such time that adequate staffing for review is in place, a member of management or their designee will develop and maintain a tickler list of all reporting requirements and due dates to ensure all reports are submitted timely.