Finding 498531 (2023-001)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
-
Year
2023
Accepted
2024-09-26
Audit: 321268
Organization: Howard County (IN)

AI Summary

  • Core Issue: The County failed to submit accurate Project and Expenditure reports, leading to material misstatements and a repeat finding from the previous audit.
  • Impacted Requirements: Noncompliance with federal reporting standards as outlined in 2 CFR 200.303 and 31 CFR 35.4(c), risking future federal funding.
  • Recommended Follow-Up: Implement a robust internal control system with clear policies and procedures to ensure accurate reporting to the Treasury.

Finding Text

FINDING 2023-001 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting Federal Agency: Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listings Number: 21.027 Federal Award Number and Year (or Other Identifying Number): FY 2023 Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion INDIANA STATE BOARD OF ACCOUNTS 13 HOWARD COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-001. Condition and Context Recipients are required to submit quarterly or annually Project and Expenditure (P&E) reports to the U.S. Department of the Treasury (Treasury). The reporting periods, as well as the respective due dates, are based upon type of recipient and its population, as well as the recipient's allocation amount. Information to be reported includes projects funded, expenditures, and contract for the appropriate reporting period. The County was classified as a metropolitan county with a population below 250,000 residents that received an allocation of more than $10 million in the Coronavirus State and Local Fiscal Recovery Funds (SLFRF) funding. As such, the initial P&E report, covering three calendar quarters from March 3, 2021 to December 31, 2021, was required to be submitted to the Treasury by January 31, 2022. The subsequent quarterly reports are to cover one calendar quarter and must be submitted to the Treasury by the last day of the month following the end of the period covered. The Deputy County Auditor prepared the quarterly reports, and the County Auditor reviewed the reports; however, the internal control was not effective and did not detect and allow correction of material misstatements prior to submission. Two of the four quarterly reports submitted during the audit period were selected for testing. For the two reports tested, all activity for the reporting period was not included, information submitted was not supported by the County's records, and the reports were not fairly presented. Errors identified included the following: Quarter 1 report (January 1, 2023 to March 31, 2023)  The Total Cumulative Obligations were understated by $2,937.  The Current Period and Total Cumulative Expenditures were overstated by $62. Quarter 3 report (July 1, 2023 to September 30, 2023)  The Total Cumulative Obligations were understated by $118,025.  The Current Period Expenditures were understated by $56,781.  The Total Cumulative Expenditures were understated by $147,930. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) 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). . . ." INDIANA STATE BOARD OF ACCOUNTS 14 HOWARD COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 31 CFR 35.4(c) states in part: "Reporting and requests for other information. During the period of performance, recipients shall provide to the Secretary periodic reports providing detailed accounting of the uses of funds. . . ." Coronavirus State and Local Fiscal Recovery Funds Compliance and Reporting Guidance, page 10, states in part: ". . . 10. Reporting. All recipients of federal funds must complete financial, performance, and compliance reporting as required and outlined in Part 2 of this guidance. Expenditures may be reported on a cash or accrual basis, as long as the methodology is disclosed and consistently applied. Reporting must be consistent with the definition of expenditures pursuant to 2 CFR 200.1. Your organization should appropriately maintain accounting records for compiling and reporting accurate, compliant financial data, in accordance with appropriate accounting standards and principles. . . ." Cause Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the County's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. These errors were due to not all expenditures being included in the P&E reports ran for the time frame. Effect Without the proper implementation of an effectively designed system of internal controls over reporting, the County could not ensure that the P&E reports submitted were accurate. In addition, not meeting the SLFRF reporting requirements increases the likelihood that the public will not have access to transparent and accurate information regarding expenditures of federal awards. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the County. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the County design and implement a proper system of internal controls, including policies and procedures, to ensure that the County provides the Treasury with complete and accurate information for the P&E report. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

Corrective Action Plan

FINDING 2023-001 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting Summary of Finding: The Deputy Auditor prepared the quarterly reports and the Auditor reviewed the reports; however, the control was not effective and did not detect and allow correction of material misstatements prior to submission. Two of the four quarterly reports submitted during the audit period were selected for testing. For the two reports tested, all activity for the reporting period was not included, information submitted was not supported by the County's records, and the reports were not fairly presented Contact Person Responsible for Corrective Action: Jessica Secrease Contact Phone Number and Email Address: 765-456-2804 Jessica.secrease@howardcountyin.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The County will follow the internal controls established, including policies and procedures to ensure that the County provides the Treasury with complete and accurate information for the P&E Report in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The Chief Deputy will continue to work with the Projects Manager to ensure the reporting is accurate and all obligations and expenditures are reported correctly before sending the information to a third-party vendor. The Auditor will review and approve any reporting prior to submission. Initialed reports will be kept within the grant file. Anticipated Completion Date: September 2024

Categories

Allowable Costs / Cost Principles Material Weakness Period of Performance Reporting Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Special Tests & Provisions

Other Findings in this Audit

  • 498532 2023-002
    Material Weakness
  • 1074973 2023-001
    Material Weakness Repeat
  • 1074974 2023-002
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $3.16M
93.563 Child Support Enforcement $920,357
16.710 Public Safety Partnership and Community Policing Grants $204,272
20.205 Highway Planning and Construction $138,093
16.575 Crime Victim Assistance $137,131
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $97,339
93.788 Opioid Str $80,187
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $64,632
97.042 Emergency Management Performance Grants $49,406
16.588 Violence Against Women Formula Grants $45,598
10.555 National School Lunch Program $39,514
93.658 Foster Care_title IV-E $17,693
93.268 Immunization Cooperative Agreements $16,860
10.553 School Breakfast Program $15,096
93.069 Public Health Emergency Preparedness $13,449
20.608 Minimum Penalties for Repeat Offenders for Driving While Intoxicated $11,788
20.600 State and Community Highway Safety $9,043
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs $5,000
20.616 National Priority Safety Programs $4,869