Finding Text
Cash Management and Reporting
Low-Income Home Energy Assistance ALN# 93.568
US Department of Health and Human Services
Passed through Oregon Housing and Community Services
Federal Grant/Contract Number: 2021ORLIEA, 2022ORLIEA, 2102ORE5C, 2101ORLWC5, 2102ORLWC6
Grant period – 2021 & 2022
Criteria – Per the 2021-2023 Master Grant Agreement. Subgrantee shall, and shall cause and shall require its subrecipients by contract to administer the program in a manner satisfactory to OHCS and in compliance with all program requirements, including but not limited to the following terms and conditions:
(8) Be responsible for maintaining an internal controls framework, satisfactory to OHCS, which assures compliance with program requirements.
(10) Maintain accurate financial records satisfactory to the department, which document, among other things, the receipt and disbursement of all funds provided through the program by the department; and have an accounting system in place satisfactory to the department, which meets, among other things, generally accepted accounting principles.
(12) Provide the department with reports, data, and financial statements, in form and substance satisfactory to the department, as may be required or requested from time to time by the department, which shall be in a format prescribed by the department.
(14) Assure that data collection and reporting, including data entry for program funded activities, be conducted through the use of an OHCS approved data collection system (such as ServicePoint and OPUS), where applicable by program requirements.
(15) Ensure that data collection, entry and reporting occur in an accurate and timely manner as satisfactory to OHCS.
Condition – The Agency did not maintain proper documentation in support of annual reporting requirements. Quarterly reports as required by the grant document were not filed. Cash request could not be substantiated nor could documentation to support amounts reimbursed be tied to supporting records.
As a result of the lack of documentation, sufficient appropriate audit evidence could not be obtained in order to test reporting and cash management .
Cause – Supporting records used to populate the required annual financial reporting were not retained by the Agency.
The Agency stated quarterly reports were not required by grantor and therefore not filed, however the Agency was unable to provide documentation to support this inconsistency with the terms and conditions of the grant agreement for the first 3 quarters of the fiscal year.
Reimbursement was provided as information was uploaded into the state pass-through system, however, as noted during our testing of eligibility; batches were uploaded months behind amounts being pledged to vendors on behalf of clients and no records were kept for amounts input for expenses outside of client assistance.
Effect – The Agency could submit incorrect information. Non-reporting to the grantor can result in sanctions or loss of future funding. The Agency could request funds that may not have adequate supporting documentation which could lead to errors and loss of funding under this program.
Questioned Costs – Not applicable.
Recommendation – Documentation should be prepared, reviewed, and retained to support the reporting. The documentation should clearly document who prepared the information, who reviewed the information, and that the reviewer considered whether the information was complete and accurate. Grant agreements should be read in detail and information relevant to report requirements be provided to the appropriate personnel to prevent not filing required reports.
Documentation should be provided that directly links the amount requested to the related expenditures to clearly document those funds are being used in a timely manner, that more was not requested than was expended, specifically what expenditures are being considered expended through these funds, and that funds requested applied to the correct period. Update policies and procedures as needed to reflect changes, if applicable.
Management’s Response – Management has reviewed and accepted the finding. See “Corrective Action Plan”.