Finding Text
U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES, PASSED THROUGH THE CALIFORNIA DEPARTMENT OF AGING AGING CLUSTER ? ALN?S 93.044, 93.045, 93.053 Pass-through Grantor Award # AP-2122-02 Finding 2022-002 Significant Deficiency and Noncompliance: Subrecipient Monitoring Significant Deficiency and Noncompliance: The Agency performed the required contract resolution process late for the fiscal years ended June 30, 2019 and 2020, and has not performed the contract resolution process for the year ended June 30, 2021. Criteria: Under the Special Terms and Conditions in Exhibit D of the AP-2122 Contract with the pass through grantor, Article X Audit Requirements states that the Agency shall have the responsibility for resolving its contracts with subcontractors to determine whether funds provided under this agreement are expended in accordance with applicable laws, regulations, and provisions of contracts or agreements. The Agency shall, at a minimum, perform Contract resolution within fifteen (15) months of the ?Financial Closeout Report?. This report is due by July 31st, following the close of each fiscal year. Therefore the Contract resolution should be performed on or before October 31st of the following year. Cause: The Agency did not have internal controls and procedures in place to initiate and perform the Contract resolution before the required dates. Effect: Significant deficiency in internal controls and noncompliance with the grant contract. A potential effect is that subcontractors could be expending funds that are not allowed under the provisions of the Federal award program (i.e. 2 CFR Part 200) and/or the State contract, which would have to be returned to the grantor. Context: The audit examined the Contract resolution performed for the years ended June 30, 2019 and 2020 and found them to be performed after the due dates of October 31, 2020 and 2021, respectively. The audit also found that the Contract resolution for the year ended June 30, 2021, to be performed by October 31, 2022, has not been performed as of the date of this audit report. This is not a repeat finding. There are no questioned costs related to this finding. Recommendation: The Agency should develop internal controls and procedures to perform the Contract resolution adequately and effectively before the required due date. At a minimum, these procedures should incorporate the required procedures as stated in the AP-2122 Contract, Article X, Items C (5) through (9). Since the procedures require a thorough knowledge of Uniform Guidance (i.e. Single Audit) Cost Principles and GAAP, the Agency should consider contracting with a knowledgeable CPA firm to perform the Contract resolution, or at a minimum, provide ?as-needed? assistance and a review of the completed process. Views of Responsible Officials: The Agency agrees with this finding.