Finding Text
2023‐002 – Real Property Status Special Reporting – Significant Deficiency in Internal Controls over
Compliance (Repeat Finding)
Federal Program Information:
Funding Agency: U. S. Department of Health and Human Services
Title: Head Start
CFDA Number: 93.600
Federal Award Identification number: N/A
Pass Through Entity: N/A
Award Year: 2022 & 2023
Condition: During our review of the SF‐429 report, we noted that the EIN number was incorrect, there
was no certifying signature, and the report was submitted after the due date.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, 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).
Under 45 CFR 75.319(a), Title to Federally‐owned property remains vested in the Federal
Government, and the non‐Federal entity must submit annually an inventory listing of Federallyowned
property in its custody to the HHS awarding agency. The Form SF‐429 is used for this reporting.
Questioned costs: None
Effect: The Organization’s real property may not be appropriately tracked by the Organization and
the Federal government without current and accurate reporting. Use of an incorrect identifying
number could cause discrepancies in Federal oversight of real property held by the Organization’s
Federal program.
Cause: The Organization does not have policies and procedures in place to ensure information is
accurate and approved and submitted in a timely manner. System problems prevented submittal
when attempted.