Finding 1166986 (2023-002)

Material Weakness Repeat Finding
Requirement
B
Questioned Costs
-
Year
2023
Accepted
2025-12-30

AI Summary

  • Core Issue: The Corporation lacks adequate internal controls and written policies for managing federal funds, leading to significant compliance deficiencies.
  • Impacted Requirements: Noncompliance with 2 CFR sections 200.302 and 200.305 risks incurring unallowable costs and potential sanctions, including cash payment withholding.
  • Recommended Follow-Up: Develop written policies for cost principles and ensure staff receive training on federal awards to improve compliance.

Finding Text

2023-002 Financial Management and Internal Controls (Continued) Compliance Requirement Allowable Costs/Cost Principles Category Significant Deficiency in Internal Control and Noncompliance Federal Agency U.S. Department of the Treasury Pass-Through Entity Puerto Rico Fiscal Agency and Financial Advisory Authority ALN 21.027 Federal Program COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Federal Agency U.S. Small Business Administration ALN 59.075 Federal Program COVID-19 - Shuttered Venue Operators Program Federal Agency U.S. Department of Homeland Security through the Federal Emergency Management Agency Pass-Through Entity Central Office for Recovery, Reconstruction and Resiliency ALN 97.036 Federal Program Disaster Grants - Public Assistance (Presidentially Declared Disasters) Cause In 2022, the Corporation became subject to Single Audit compliance requirements for the first time. However, it underestimated the complexity of navigating the intricate laws, regulations, and financial management requirements associated with federal funds. The lack of prior experience in implementing adequate internal controls, coupled with the absence of established written policies, contributed to challenges in ensuring compliance with federal cost principles and financial reporting obligations. Effect Failure to comply with 2 CFR sections 200.302 and 200.305 could result in the Corporation incurring unallowable costs. Consequently, the Corporation may face temporary withholding of cash payments until the deficiency is corrected. Additionally, continued noncompliance could lead to further sanctions, including the suspension or termination of federal funding for the program, ultimately impacting the Corporation’s ability to fulfill its obligations and sustain operations. Questioned Costs None. Repeated Item Refer to Item No. 2022-002 in the Summary Schedule of Prior Audit Findings. Recommendation The Corporation should draft written policies under subpart E, Cost Principles of 2 CFR Part 200. In addition, the staff involved with federal funds should take courses on federal awards. Views of responsible officials Refer to Unaudited Corrective Action Plan.

Corrective Action Plan

Action Item Title 2023-002 – Federal Award Findings Status (Open: In-process) Condition Written Policies The Corporation has no written policies for determining whether the activities allowed or unallowed and the allowability of costs as described in subpart E, Cost Principles of 2 CFR Part 200. Identified root cause In 2022, the Corporation became subject to Single Audit compliance requirements for the first time. However, it underestimated the complexity of navigating the intricate laws, regulations, and financial management requirements associated with federal funds. The lack of prior experience in implementing adequate internal controls, coupled with the absence of established written policies, contributed to challenges in ensuring compliance with federal cost principles and financial reporting obligations. Grantee resolution plan Written Policies The Corporation received federal funds for the first time in 2022. For the purposes of purchases or acquisitions, the Corporation is governed by Law of the General Service Administration for the Centralization of Government Purchases in Puerto Rico, Law No. 73 of 2019, which establishes the uniform purchasing process for acquisitions by the Commonwealth. The Corporation will adopt regulations for the use and disbursement of federal funds and comply with the federal regulations. Completion date By December 31, 2025. Name and Title of contact: Linnette Dávila Alemán- Financial and Budget Assistant Manager Phone: 787-724-4747 ext. 2105 Email: ldavila@cba.pr.gov Jetppeht Pérez de Corcho Morgado – General Manager Phone: 787-724-4747 ext. 2102 Email: jperez@cba.pr.gov

Categories

Allowable Costs / Cost Principles

Other Findings in this Audit

  • 1166977 2023-002
    Material Weakness Repeat
  • 1166978 2023-003
    Material Weakness Repeat
  • 1166979 2023-004
    Material Weakness Repeat
  • 1166980 2023-005
    Material Weakness Repeat
  • 1166981 2023-006
    Material Weakness Repeat
  • 1166982 2023-002
    Material Weakness Repeat
  • 1166983 2023-004
    Material Weakness Repeat
  • 1166984 2023-005
    Material Weakness Repeat
  • 1166985 2023-006
    Material Weakness Repeat
  • 1166987 2023-004
    Material Weakness Repeat
  • 1166988 2023-005
    Material Weakness Repeat
  • 1166989 2023-006
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
59.075 SHUTTERED VENUE OPERATORS GRANT PROGRAM $1.62M
97.036 DISASTER GRANTS - PUBLIC ASSISTANCE (PRESIDENTIALLY DECLARED DISASTERS) $523,590
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $502,779