Finding 544363 (2024-003)

Significant Deficiency
Requirement
L
Questioned Costs
-
Year
2024
Accepted
2025-03-31
Audit: 351003
Organization: Ontrack Inc. (OR)
Auditor: Clark Nuber P S

AI Summary

  • Core Issue: There is a significant deficiency in internal controls leading to noncompliance with reporting requirements for subawards over $30,000.
  • Impacted Requirements: The Organization failed to register and report subawards in the FSRS as mandated by 2 CFR Part 170.
  • Recommended Follow-Up: Implement new policies and procedures to ensure compliance with federal award reporting requirements.

Finding Text

Significant deficiency in internal controls and noncompliance with the reporting requirements. Federal Agency: Department of Health and Human Services Program Title: Substance Abuse and Mental Health Services Projects of Regional and National Significance Assistance Listing Number: 93.732 Award Numbers and Years: All awards Criteria In accordance with 2 CFR Part 170, recipients of grants or cooperative agreements who make first tier subawards of $30,000 or more are required to register in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) and report subaward data through FSRS as required by appendix A to Part 2 CFR part 170. Condition/Context During reporting compliance testing for the year ended June 30, 2024, for one of one subaward made the Organization did not report the subaward made greater than $30,000 in FSRS. Cause The Organization did not have internal controls in place to ensure that all subawards made greater than $30,000 were included in FSRS. Effect First tier subawards of greater than $30,000 were not reported in FSRS. Questioned Costs Not applicable Repeat Finding Not a repeat finding. Recommendation We recommend the Organization implement policies and procedures for procuring goods and services under federal awards that meet the requirements of the Uniform Guidance. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Corrective Action Plan

Contact Person Mark Bell Director of Finance vcc.m.bell@ontrackroguevalley.org Explanation and Specific Reasons for Disagreement With the Audit Finding or That Corrective Action is not Required (if Applicable) No disagreement. Corrective Action Planned 1. Establish FSRS Reporting Policy and Procedures o The Organization will develop and implement a formal Subaward Reporting Policy to ensure that all first-tier subawards of $30,000 or more are reported in FSRS in compliance with 2 CFR Part 170. 2. Assign Responsibility and Oversight o A specific staff member within the Grants department will be designated as the FSRS Reporting Coordinator and will be responsible for verifying the completeness and accuracy of subaward reporting and for timely submission to FSRS. o A pre-submission review will be conducted by the FSRS Reporting Coordinator to verify that subawards over $30,000 are captured and reported. 3. Implement Internal Controls and Review Checkpoints o All subawards will be reviewed as part of the pre-award and post-award grant workflow to determine FSRS applicability. o A pre-submission review will be conducted by the Grants Compliance Officer to verify that subawards over $30,000 are captured and reported. 4. Monitoring and Audit Trail Documentation o FSRS submissions will be documented and retained in the grant file along with confirmation of submission and reporting screenshots. Anticipated Completion Date September 30, 2025

Categories

Subrecipient Monitoring Reporting Significant Deficiency Internal Control / Segregation of Duties

Other Findings in this Audit

  • 544361 2024-002
    Material Weakness
  • 544362 2024-002
    Material Weakness
  • 544364 2024-003
    Significant Deficiency
  • 1120803 2024-002
    Material Weakness
  • 1120804 2024-002
    Material Weakness
  • 1120805 2024-003
    Significant Deficiency
  • 1120806 2024-003
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
14.239 Home Investment Partnerships Program $744,977
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $458,307
14.235 Supportive Housing Program $210,903
93.959 Block Grants for Prevention and Treatment of Substance Abuse $83,112
93.732 Mental and Behavioral Health Education and Training Grants $12,741
21.027 Coronavirus State and Local Fiscal Recovery Funds $10,381