Finding Text
CLAYTON COUNTY COMMUNITY SERVICES AUTHORITY, INC.
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
Federal Award Findings and Questioned Costs
June 30, 2021
Comment # 2021-006
THE AUTHORITY SHOULD ESTABLISH FORMAL POLICIES AND PROCEDURES FOR OBTAINING,
RECORDING, AND REPORTING NON-FEDERAL MATCH
HEAD START AND EARLY HEAD START PROGRAMS
Federal Assistance Listing # 93.600
(Questioned Costs - Undetermined)
Condition:
During our audit, we noted that the Authority does not have formal policies and procedures developed that address the requirements to obtain, record and report non-federal match as required by the Department of Health and Human Services - Head Start Programs. It is a statutory requirement for grantees to provide such match as specified under the Head Start Act Section 640(b). Administrative requirements are codified in 45 CFR § 75.306 which states in the Act that a grantee agency must provide 20 percent of the total costs of the Head Start program during a budget period unless a waiver has been granted. During the audit of the year ended June 30, 2021, the Authority had grants awards requiring non-federal match (in-kind) as set forth in the notice of awards (NOA); however, the general ledger did not disclose any in-kind recorded or reported that met the requirements of the federal regulations. We did not observe any evidence of non-federal match being obtained, valued and recorded in accordance with generally accepted principles and federal regulations nor were we presented evidence that a responsible official with HHS approved of a wavier (other than a waiver for the CARES Act
funding documented in the NOA.
Context:
We reviewed grants awarded during the audit period to determine the level of funding granted and the required nonfederal match to be provided by the grantee (the Authority).
Criteria:
In accordance with section 640(b) of the Act, federal financial assistance to a grantee will not exceed 80 percent of the approved total program costs. A grantee must contribute 20 percent as non-federal match each budget period. The responsible HHS official may approve a waiver of all or a portion of the non-federal match requirement on the basis of the grantee’s written application submitted for the budget period and any supporting evidence the responsible HHS official requires. In deciding whether to grant a waiver, the responsible HHS official will consider the circumstances specified at section 640(b) of the Act and whether the grantee has made a reasonable effort to comply with the non-federal match requirement. In addition to internal policy of the Authority, generally accepted accounting principles, Government Auditing Standards and the Uniform Guidance.
Effect:
The transaction could result in the Authority refunding funds to HHS for the failure to obtain and report the required nonfederal match.
Cause:
The failure of the Authority to have formal policies and procedures governing the requirements of obtaining, valuing and recording non-federal match as required by federal regulations. Management and the board of directors must have proper oversight and governance over the tracking, valuing and reporting of non-federal match.
Recommendation:
We recommend that the board of directors and management immediately identify all grants and contracts requiring nonfederal match. The types of non-federal match should be gathered from the various sources, valued using accepted methodologies and techniques, recorded for the appropriate period and reported in accordance with generally accepted accounting principles and federal regulations.
Views of Responsible Officials and Planned Corrective Actions:
The management of Clayton County Community Services Authority, Inc. has reviewed the above referenced finding. The agency has always utilized the Georgia Pre-K reimbursement it receives during the fiscal year as the matching component for Head Start. The total reimbursement for the reporting period was $814,374. While this amount was not recorded in the general ledger as matching, all matching expenditures were recorded in all the SF425 that were submitted to the funding agency. The agency has all the proper documentation for further review related to Non-Federal Share Matching. The agency has all documentation related to this reimbursement as well as prior audit periods where this amount has been utilized and accepted as the matching component.
The agency will move forward with the development of providing proper oversight and governance of tracking and reporting non-federal match.