Finding Text
1. Reporting-Electronic Absentee Systems for Elections (EASE 3.0) Finding Number: 2025-002 Assistance Listing (AL) Number and Title: AL #12.219, Electronic Absentee Systems for Elections (EASE 3.0) Federal Award Identification Number and Year: H98210-23-BAA-0000, 2023 Federal Agency: Department of Defense Compliance Requirement: Reporting Requirement Pass-Through Entity: None Repeat Finding from Prior Audit? No Prior Audit Finding Number: None Noncompliance and Material Weakness 2 CFR § 1104.1 gives regulatory effect to the Department of Defense for 2 CFR § 200.328-329 which states: 2 CFR § 200.328(b) states the Federal entity agency or pass-through entity must collect financial reports no less than annually. The Federal agency or pass-through entity may not collect financial reports more frequently than quarterly unless a specific condition has been implemented in accordance with § 200.208. To the extent practicable, the Federal agency or pass-through entity should collect financial reports in coordination with performance reports. Page 4 Noncompliance and Material Weakness – (Continued) 2 CFR 200.328(c) stipulates that the recipient or subrecipient must submit financial reports as required by the Federal award. Reports submitted annually by the recipient or subrecipient must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period. From the EASE 3.0 Grant Agreement the recipient shall report the following: Quarterly Progress Reports. The recipient shall provide a quarterly progress report associated with the EASE 3.0 Program no later than thirty (30) calendar days after the end of the quarter. Special Report(s): In the event that activities occur between the scheduled reporting dates, which have significant impact upon the cooperative agreement, the recipient shall inform both the Grants Office, Administrative Grants Officer and FVAP Program Officer immediately when the following types of conditions become know: (a) Problems, delays, or adverse conditions, which will materially impair the ability to meet the objective of the award. This disclosure must include a statement of the action taken, or contemplated, and any assistance needed to resolve the situation. (b) Favorable developments that enable meeting time schedules and objectives sooner or at less cost than anticipated or producing more beneficial results than originally planned. Data Collection Plan All data requirements to be completed and delivered to FVAP within 60 days of each federal general election. Schedule of Data Reporting Requirements Training with FVAP within 30 days of receiving EASE grant funds. Specify the system(s) that were built/improved using EASE grant funds (system for electronic transmission of ballots; system for tracking mailed ballots; system for the use of digital signature verification; other. State the date of deployment for these system(s). Collect the data fields as described on the Data Fields document and record the data on the EASE Grants Data Collection Instrument under their respective columns. Page 5 Noncompliance and Material Weakness – (Continued) Provide any data from previous election cycles (if already collected). This data will be used for comparison purposes and is acceptable in its original format. Collecting and recording non-UOCAVA data to be used for comparison purposes is optional. Quarterly Federal Financial Reports The recipient shall prepare a quarterly financial report (Standard Form 425) in accordance with the Uniform Guidance at 2 CFR 200 and 32 CFR32.52, to the DLNSEO Program Officer, Grants Officer and Administrative Grants Officer. These reports shall also include information on repayment of grants and disbursement of these funds in its quarterly financial reports, associated with the EASE 3.0 Programs. Quarterly Disbursement Schedules The recipient shall provide quarterly disbursement schedules to justify its invoice requests, delivered in coordination with requests for payments. During our testing of the reporting requirements the County did not submit or provide Quarterly Progress Reports, Data Collection Plan, Quarterly Federal Financial Reports or Quarterly Disbursement Schedules. As a result, we have qualified the opinion over this grant. Failure to have the proper controls in place to ensure the completion and submission of the required reports could result in the Department of Defense taking action against the County for failure to comply with programmatic requirements. Failure to monitor the reporting function of a federal program and submit financial reports timely could jeopardize future funding. To help ensure compliance with federal grand guidelines, the Board of Elections should be aware of when reports need to be submitted and ensure reports are being submitted within the specified timeframe.