Finding Text
Assistance Listing Number(s): 93.575 Name of Federal Program or Cluster: CCDF Cluster Name of Federal Agency: Department of Health and Human Services Name of Pass-through Entities: Iowa County Department of Social Services, Jefferson County Human Services Department, Waukesha County Department of Health and Human Services, Dane County Department of Human Services, Supporting Families Together Association, Inc., and 4C-for Children, Inc. Pass-through Entities Identifying Numbers: 2024-04, 87242, 437002-G16-0000756-R05-02, and 437002- G16-0000756-R06-02 Award Periods: July 1, 2023 through June 30, 2024, July 1, 2024 through June 30, 2025, and January 1, 2024 through December 31, 2024 Criteria or Specific Requirement: In accordance with 2 CFR Part 200, Subpart D (§200.306) non-federal entities must meet matching, level of effort, and earmarking requirements, including proper documentation and monitoring to demonstrate compliance. The Uniform Guidance requires that controls be in place to ensure that these compliance requirements are consistently met per §200.303. Condition: The entity did not have adequate internal controls in place to ensure that non-federal match contributions and earmarking calculations were properly tracked, documented, and verified. Cause: There are an absence of formal policies and procedures, insufficient training of staff responsible for compliance, and a lack of segregation of duties related to review and approval of match contributions and earmarking calculations. Effect or Potential Effect: There is an increased risk that the entity may not be in compliance with applicable matching and earmarking requirements. Recommendation: We recommend that the entity implement formal written policies and procedures for tracking and documenting matching contributions and earmarking calculations. These procedures should include regular reconciliations, management review, and appropriate documentation retention. Additionally, staff should be trained on federal compliance requirements, and responsibilities should be clearly assigned to ensure adequate segregation of duties. Views of Responsible Officials: Management agrees with the finding and is considering options to implement the recommendations.