Finding Text
Finding Number: 2021-001
Federal Programs:
All federal financial assistance programs.
Category:
Internal Control/Compliance - Material Weakness
Compliance Requirement:
Reporting - Data Collection Form
Condition:
The Office of the Advocate for the Elderly of the Commonwealth of Puerto Rico (OAE) submitted the data
collection form for the year ended September 30, 2020, to Federal Clearinghouse after its due date. Also, the
current single audit for the year ended September 30, 2021, is being completed and submitted after the
corresponding date.
Criteria:
2 CFR Part 200, Subpart C, Section 200.512 established that the audit shall be completed and the data collection
form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section
shall be submitted within the earlier of 30 days after receipt of the auditor's report(s), or nine months after the
end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for
audit. Unless restricted by law or regulation, the auditee shall make copies available for public inspection.
Cause:
OAE's Single Audit Report for fiscal year 2020 was submitted on January 12, 2023. The main causes were
recurrent delays in engaging the auditors and general planning of the process and the extended disruptions caused
by COVID-19. For fiscal year 2021, the main causes were the delays experienced in the contract process to
engage the external auditors and delays in retrieving the relevant support documents in custody of the Puerto
Rico Department of Treasury. All the disbursements are processed by the subject Department.
Effect:
OAE may be subject to sanction, as described in the Uniform Guidance, Section 225 titled "Sanctions", in cases
of continued inability to have an audit conducted in accordance with this part, Federal agencies and pass-through
entities shall take appropriate actions using sanctions such as: (a) withholding a percentage of federal award until
the audit is completed satisfactorily; (b) withholding or disallowing overhead cost; (c) suspending federal award
until the audit is conducted; or (d) terminating the federal award.
Questioned Cost:
None.
Recommendation:
We recommend management to formalize a plan to monitor the single audit process, including the engagement
of the external auditors, the completion of all required steps, including the access to the required documentation,
as well as an itinerary of every relevant step to perform, complete and submit single audit during the required
period.
Management Response:
Management agrees with the observation. Management recognizes that a delay will be experienced with respect
to 2021. However, Management adopted a plan to reduce the delay for 2022 and to comply with the deadlines
for the years after 2022.