Southwest Region Planning Commission

Failure to Identify Single Audit Requirement and Federal Awards (Significant Deficiency in Internal Control) Criteria: In accordance with 2 CFR §200.501, a non-federal entity that expends $750,000 or more in federal awards during the fiscal year is required to have a Single Audit conducted. Additionally, 2 CFR §200.510(b) requires the auditee to prepare a Schedule of Expenditures of Federal Awards (SEFA) that accurately identifies all federal awards expended, including Assistance Listing (ALN) numbers and pass-through entity information.Condition: The auditee did not identify that it met the threshold requiring a Single Audit. In addition, the auditee did not have adequate processes in place to identify and track all federal funds received and expended during the fiscal year. As a result, the initial SEFA prepared by the auditee was incomplete and did not include all federal awards.Context: The deficiency affected the auditee’s process for identifying and reporting federal expenditures across all applicable programs during the fiscal year.Cause: The deficiency is due to a lack of internal controls over identifying federal funding sources and monitoring cumulative federal expenditures, as well as insufficient understanding of Uniform Guidance requirements related to Single Audits and SEFA reporting.Effect: Failure to identify all federal awards and the requirement for a Single Audit resulted in incomplete financial reporting and increases the risk that compliance requirements applicable to federal programs may not be identified or followed. This condition could result in noncompliance with federal regulations and inaccurate reporting of federal expenditures.Recommendation: We recommend that the auditee implement and document procedures to: • Identify all sources of federal funding, including reviewing grant and contract agreements for federal involvement • Track federal expenditures by program and funding source throughout the year • Perform a year-end assessment to determine whether the Single Audit threshold has been met • Ensure the SEFA is complete and accurate, including all required elements • Provide training to relevant personnel on Uniform Guidance and Single Audit requirements Views of Responsible Officials: Management agrees with the finding and has developed a corrective action plan to address the deficiencies noted. The plan includes implementing procedures to identify and track federal awards and ensure compliance with Single Audit requirements, and will be implemented during the next fiscal year. Auditor’s Conclusion: This deficiency represents a significant deficiency in internal control over financial reporting and internal control over compliance, as the controls over identifying, tracking, and reporting federal awards were not sufficient to ensure a complete and accurate SEFA or timely identification of the need for a Single Audit.

Corrective Action Planned: The auditee acknowledges that it did not have adequate procedures in place to identify all federal funding sources, track cumulative federal expenditures, and determine the applicability of Single Audit requirements.• Federal Funding Identification Procedures: Establish formal procedures to review all grant agreements, contracts, and funding documents to identify federal funding sources, including Assistance Listing (ALN) numbers and pass-through entity information. • Centralized Tracking of Federal Expenditures: Implement a tracking mechanism ( e.g., spreadsheet or accounting system enhancement) to record and monitor all federal expenditures by program throughout the fiscal year. • Periodic Monitoring of Single Audit Threshold: Perform quarterly reviews of cumulative federal expenditures to determine whether the dollar threshold (currently $1 million) for a Single Audit has been met. • SEFA Preparation and Review Controls: Develop a standardized process for preparing the Schedule of Expenditures of Federal Awards (SEFA), including a supervisory review to ensure completeness and accuracy prior to issuance. • Training and Awareness: Provide training to key personnel involved in financial reporting and grant management on Uniform Guidance requirements, including SEFA preparation and Single Audit thresholds. Anticipated Completion Date: September 30, 2026 Planned Monitoring and Follow-Up: Management will periodically review compliance with the new procedures and controls to ensure that all federal funding is properly identified, tracked, and reported, and that Single Audit requirements are evaluated timely.