Finding 517197 (2024-001)

Late Submission of Form ED-209 Assistance Title: COVID-19 - Economic Adjustment Assistance - Coronavirus Aid, Relief, and Economic Security (CARES) Act Revolving Loan Fund Assistance Listing Number: 11.307 Federal Agency: U.S. Department of Commerce Type of Finding: Significant Deficiency and Noncompliance Category of Finding: Audit Requirements Known Questioned Costs: $0 Likely Questioned Costs: $0 Criteria Per the CARES Act Revolving Loan Fund Standard Terms and Conditions, the Form ED-209 must be submitted within 30 days after the reporting period ending June 30, 2024. Condition The Organization did not submit Form ED-209 within the required timeframe. The initial submission occurred on September 25, 2024, which was after the 30-day deadline. Furthermore, errors identified at the federal level necessitated a resubmission of the form. The final submission was completed on October 18, 2024, resulting in a delayed submission beyond the allowable period. Cause The oversight occurred due to inadequate internal controls in reviewing the Form ED-209. Subsequent errors identified by federal reviewers required corrections, further extending the submission timeline. Effect Late submission of required federal reports constitutes noncompliance with federal reporting requirements. This may result in increased scrutiny from federal agencies, potential penalties, or impacts on future funding and grant opportunities. Repeat Finding This is not a repeat finding. Recommendation We recommend that the Organization implement stricter internal controls and monitoring procedures to ensure all federal reports, including Form ED-209, are prepared accurately and submitted within the required deadlines. Additionally, a review process should be established to promptly address and correct any errors identified by federal agencies to prevent further delays. Management’s Response Management concurs with this finding. See Management’s Response and Corrective Action plan section.