Finding Text
Assistance Listing Number, Federal Agency, and Program Name 93.044, 93.045, 93.053, U.S. Department of Health and Human Services, Special Programs for the Aging, Title III, Part B, Grants for Supportive Services and Senior Centers; Special Programs for the Aging, Title III, Part C, Nutrition Services, and Nutrition Services Incentive Program (Aging Cluster) Federal Award Identification Number and Year EX24040 (2024); 21 IHEA 160179 (2021); EX23077 (2023); CON1357567 (2024) Pass through Entity Larimer County and Denver Regional Council of Governments Finding Type Material weakness Repeat Finding No Criteria Per 2 CFR 200.303, the recipient must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the 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 Organization lacked adequate controls to ensure reviews were performed by a different individual than the one responsible for preparing monthly financial reporting, calculations of per unit activity, and requests for reimbursement. Questioned Costs N/A If Questioned Costs are not Determinable, Description of Why Known Questioned Costs Were Undetermined or Otherwise Could not be Reported No questioned costs were identified as the result of this finding Identification of How Questioned Costs Were Computed N/A Context During our walkthrough to understand management’s processes and internal controls to ensure compliance with financial reporting, we observed that the same individual was responsible for preparing, finalizing, and submitting financial reports for passthrough awards. This process includes accumulating cost activity incurred for the period from the general ledger for the Denver Regional Council of Governments awards, calculating revenue based on a fixed fee per service under the Larimer County awards, and accumulating and reporting matching contributions under all the awards. There was no evidence of an independent review or approval prior to submission. Cause and Effect A lack of segregation of duties and independent review increases the risk of material errors in financial reporting, including misstatements of fee based revenue on the SEFA and inaccuracies in meeting match requirements. Recommendation We recommend the Organization implement a formal control requiring an independent review of all financial reports prior to submission to the funding agency. This review should be performed by an individual who is not involved in the preparation of the reports. Views of Responsible Officials and Planned Corrective Actions Management concurs with the finding. We recognize that for the Denver Regional Council of Governments (DRCOG) and Larimer County awards the processes for accumulating cost activity, calculating per unit revenue, and reporting matching contributions lacked documentation of an independent review prior to submission. While management maintains that the data submitted was accurate and supported by the general ledger, we acknowledge that the absence of a formal "preparer vs. approver" workflow does not meet the standards outlined in 2 CFR 200.303. Corrective Action Plan: 1. Standardization of Financial Reporting Workflow: A formal segregation of duties for all federal and pass through reimbursement requests and financial reports has been implemented. Effective immediately, the individual responsible for accumulating cost data and calculating per unit activity (preparer) is prohibited from being the reviewer. 2. Implementation of Approval Process: All reports must now be submitted by the preparer to the designated reviewer for approval via email prior to submission. An approval response from the reviewer is required prior to submission to the awarding agency. 3. Staff Training: All grants management and accounting personnel have been briefed on the requirements of 2 CFR 200.303, specifically regarding the necessity of documented internal controls to provide reasonable assurance of compliance.