Finding 383779 (2023-003)

Material Weakness
Requirement
BCL
Questioned Costs
-
Year
2023
Accepted
2024-03-22

AI Summary

  • Core Issue: There is a material weakness in internal controls over compliance, specifically regarding documentation and timely reporting.
  • Impacted Requirements: Non-compliance with 2 CFR 200.303(a) and 2 CFR 200.329(c)(1) due to lack of authorized personnel review and late submissions of reports.
  • Recommended Follow-Up: Ensure documentation of authorized reviews is retained and implement backup measures for timely report filing, especially during employee absences.

Finding Text

Type of Finding: Material Weakness in Internal Control over Compliance Pass-Through Agency: Pacific Mountain Workforce Development, King County Regional Homelessness Authority, City of Bellevue, King County, City of Des Moines, United States Conference of Catholic Bishops Pass-Through Number(s): TCJN-ARPA-011-PY21, DA-202201-00320, DA-202212-01125, DA-230, 10270, 6204070, DA-251, SLFRP4086, 20-WA-146, 20-WA-146LT, S20-WA-500, 90ZU0386-3-0, 90ZU0386-3-0 Award Period: May 1, 2022 to June 30, 2023, January 1, 2022 to December 31, 2022, January 1, 2023 to December 31, 2023, January 1, 2022 to December 31, 2022, January 1, 2023 to December 31, 2024, January 1, 2022 to December 31, 2024, January 1, 2022 to December 31, 2022, September 1, 2021 to August 31, 2022, October 1, 2020 to September 30, 2023, August 19, 2022 to September 30, 2026, October 1, 2019 to September 30, 2023, January 1, 2022 to December 31, 2022, January 1, 2023 to December 31, 2023 Criteria or specific requirement: 2 CFR 200.303(a) states that a non-federal entity must "Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with 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)". In addition, 2 CFR 200.329(c)(1) states that the non-federal entity must submit performance reports at the interval required by the federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Condition: During testing of indirect costs, cash management, and reporting, it was noted that documentation was not retained secondary review of financial reports, performance reports, or special reports. In addition, during testing of reporting, it was noted that some reports were not filed timely and reported some incorrect demographics. Questioned costs: None. Context: (21.027) For allowable costs (indirects), a sample of 8 was made from a population of 63 reimbursement requests for the major program. Of the 8 sampled, all were missing evidence of authorized personnel review. For reporting, a sample of 16 monthly, quarterly, and annual reports (varied) was made from a population of 91 total reports. Of the 16 sampled, 15 were missing evidence of authorized personnel review. In addition, 1 monthly performance report was not filed timely. (64.033) For allowable costs (indirects) and cash management, a sample of 8 was made from a population of 35 reimbursement requests for the major program. Of the 8 sampled, all were missing evidence of authorized personnel review. For reporting, a sample of 11 monthly, quarterly, and annual reports (varied) was made from a population of 40 total reports. Of the 11 sampled, all were missing evidence of authorized personnel review. In addition, 2 quarterly performance reports reported some incorrect demographics. (93.676) For allowable costs (indirects) and cash management, a sample of 3 was made from a population of 12 reimbursement requests for the major program. Of the 3 sampled, all were missing evidence of authorized personnel review. For reporting, a sample of 5 monthly and quarterly reports (varied) was made from a population of 16 total reports. Of the 5 sampled, all were missing evidence of authorized personnel review. In addition, 1 quarterly performance report was not filed timely and reported some incorrect demographics. Cause: Documentation is not retained as proof of authorized personnel review on monthly, quarterly, and annual financial, performance and special reports. For late filing, controls are not in place to ensure that timely report filings are made in the event that an employee responsible for report submission is out of office during the due date. Effect: Without adequate documentation and controls in place to ensure costs are reasonable and intended for the program charged, CCS could incorrectly charge expenditures to the federal program, report fraudulent expenditures, or not request appropriate reimbursement that CCS is entitled to under the terms of the grant. Inadequate allocation of indirect costs to federal programs may result in noncompliance with grant regulations, which could result in penalties or repayment obligations. The late filing of reports can present risks, such as outdated and unreliable information or the inability to detect potential fraud or irregularities. In addition, delayed reports can impede regulatory authorities’ ability to monitor compliance, detect patterns or trends, and assess risks in a timely manner. Repeat Finding: No. Recommendation: CLA recommends that documentation is retained as proof of authorized personnel review. In addition, CCS should consider backup measures to ensure the timely filing of financial, performance and special reports even during the absence of an employee. Views of responsible officials: There is no disagreement with the audit finding.

Categories

Allowable Costs / Cost Principles Cash Management Subrecipient Monitoring Material Weakness Reporting Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 383771 2023-003
    Material Weakness
  • 383772 2023-003
    Material Weakness
  • 383773 2023-003
    Material Weakness
  • 383774 2023-003
    Material Weakness
  • 383775 2023-003
    Material Weakness
  • 383776 2023-003
    Material Weakness
  • 383777 2023-003
    Material Weakness
  • 383778 2023-003
    Material Weakness
  • 383780 2023-003
    Material Weakness
  • 383781 2023-003
    Material Weakness
  • 383782 2023-003
    Material Weakness
  • 383783 2023-003
    Material Weakness
  • 383784 2023-002
    Significant Deficiency
  • 383785 2023-002
    Significant Deficiency
  • 383786 2023-002
    Significant Deficiency
  • 383787 2023-001
    Significant Deficiency
  • 383788 2023-001
    Significant Deficiency
  • 383789 2023-001
    Significant Deficiency
  • 383790 2023-004
    Significant Deficiency
  • 960213 2023-003
    Material Weakness
  • 960214 2023-003
    Material Weakness
  • 960215 2023-003
    Material Weakness
  • 960216 2023-003
    Material Weakness
  • 960217 2023-003
    Material Weakness
  • 960218 2023-003
    Material Weakness
  • 960219 2023-003
    Material Weakness
  • 960220 2023-003
    Material Weakness
  • 960221 2023-003
    Material Weakness
  • 960222 2023-003
    Material Weakness
  • 960223 2023-003
    Material Weakness
  • 960224 2023-003
    Material Weakness
  • 960225 2023-003
    Material Weakness
  • 960226 2023-002
    Significant Deficiency
  • 960227 2023-002
    Significant Deficiency
  • 960228 2023-002
    Significant Deficiency
  • 960229 2023-001
    Significant Deficiency
  • 960230 2023-001
    Significant Deficiency
  • 960231 2023-001
    Significant Deficiency
  • 960232 2023-004
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.498 Provider Relief Fund $1.19M
93.676 Unaccompanied Alien Children Program $336,758
93.045 Special Programs for the Aging_title Iii, Part C_nutrition Services $320,591
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $292,906
14.267 Continuum of Care Program $273,963
64.024 Va Homeless Providers Grant and Per Diem Program $236,651
93.959 Block Grants for Prevention and Treatment of Substance Abuse $230,402
14.241 Housing Opportunities for Persons with Aids $218,707
14.239 Home Investment Partnerships Program $200,000
64.033 Va Supportive Services for Veteran Families Program $176,453
93.788 Opioid Str $136,967
21.027 Coronavirus State and Local Fiscal Recovery Funds $96,016
94.002 Retired and Senior Volunteer Program $65,455
14.231 Emergency Solutions Grant Program $54,666
93.242 Mental Health Research Grants $43,283
14.228 Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii $31,698
93.224 Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $27,170
14.218 Community Development Block Grants/entitlement Grants $25,426
93.958 Block Grants for Community Mental Health Services $23,850
93.914 Hiv Emergency Relief Project Grants $23,456
20.513 Enhanced Mobility of Seniors and Individuals with Disabilities $19,593
93.053 Nutrition Services Incentive Program $12,420
93.778 Medical Assistance Program $6,835
97.024 Emergency Food and Shelter National Board Program $5,431
10.569 Emergency Food Assistance Program (food Commodities) $1,589
93.044 Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers $1,458
93.052 National Family Caregiver Support, Title Iii, Part E $244