Thames Vallley Council for Community Action, Inc.

Finding 2025.002 – Reporting – Significant Deficiency and Noncompliance Information on the Federal Programs Assistance Listing Number 93.568 - Low-Income Home Energy Assistance, U.S. Department of Health and Human Services, Pass-Through Entity: State of Connecticut Department of Social Services, Award Number: 23DSS4301ZK; 22DSS1501ZK Assistance Listing Number 93.667 - Social Services Block Grant, U.S. Department of Health and Human Services, Pass-Through Entity: State of Connecticut Department of Social Services, Award Number: 22DSS1501ZK, Pass-Through Entity: Senior Resources Agency on Aging, Award Number: Not available, Pass-Through Entity: Connecticut Association for Community Action, Award Number: 18DSS5001FB. Assistance Listing Number 21.027 - COVID-19 Coronavirus State and Local Fiscal Recovery Funds, U.S. Department the Treasury, Pass-Through Entity: United Way of Southeastern Connecticut, Award Number: 23OECARRPUWS; 24DOH100HUBDA, Pass-Through Entity: City of Norwich, Award Number: Not available, Pass-Through Entity: Senior Resources Agency on Aging, Award Number: N4HSE, Pass-Through Entity: LEARN Regional Education Services, Award Number: Not Available, Pass-Through Entity: Eastern Connecticut Workforce Investment Board, Inc., Award Number: Not Available, Pass-Through Entity: Griswold Public Schools, Award Number: Not Available, Pass-Through Entity: LEARN Regional Education Services, Award Number: Not Available, Pass-Through Entity: Connecticut Office of Early Childhood, Award Number: 25OECARPCDC01179; 23OEC1XAG1TVC, Pass-Through Entity: Department of Aging and Disability, Award Number: 23DRENPTVCCARPA, Pass-Through Entity: State of Connecticut Department of Social Services, Award Number: 21DSS6101ZK; 22DSS611ZK, Pass-Through Entity: Connecticut Department of Mental Health and Addiction Services, Award Number: 23MHA2101. Criteria In accordance with §200.328 Financial Reporting and 200.329, Monitoring and Reporting Program Performance, recipients and subrecipients must submit financial and performance reports as required by the award. Condition For the year ended March 31, 2025, certain reports for the above mentioned grants were not filed within the required timeline as set by the pass-through. Cause The Council did not have adequate controls in place to ensure compliance with the requirements regarding timely reporting as set forth in their federal award contracts. Effect or Potential Effect Inadequate controls over the preparation and review of reporting requirements resulted in the untimely filing of required reports causing there to be noncompliance with the reporting requirement set forth by Uniform Guidance. Questioned Costs None Recommendation We recommend management review their controls process over the reporting criteria to ensure that all reports are submitted within a timely manner as required by the federal award agreements. Views of Responsible Officials TVCCA recognizes the validity of this finding. A centralized reporting calendar will be created to track all federal, state, and other required reporting deadlines. The finance team will strengthen internal controls by adding reporting signoffs to the master close checklist to ensure timely completion. Additionally, reporting progress will be monitored quarterly as part of the quarter-end review process.

Finding 2025.003 – Period of Performance – Significant Deficiency and Noncompliance Assistance Listing Number 14.267 - Continuum of Care, U.S. Department of Housing and Urban Services, Pass-Through Entity: State of Connecticut Department of Housing, Award Number: 24DOH0901CX, Pass-Through Entity: United Way of Southeastern Connecticut, Award Number: 21DOH1001DA Criteria A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award's period of performance that was authorized by the federal awarding agency or pass-through entity (2 CFR sections, 200.308, 200.309 and 200.403(h)). Condition Certain expenses were charged to the grant that were not properly obligated prior to the end of the grant period. Purchase orders were issued without placing the actual order, or the item was ordered after the period of performance concluded. Cause The Council did not have adequate policies, procedures and controls in place to ensure compliance with the requirements regarding period of performance. Effect or Potential Effect Inadequate controls over period of performance led to expenses charged to the grant that were not incurred during the required period of performance. Questioned Costs $2,113 Context We selected 5 expenditures for testing over the period of performance requirement. Out of the 5 expenditures tested, we noted 2 instances where expenditures were not spent or obligated appropriately in the right grant period. Identification as a Repeat Finding This is not a repeat finding. Recommendation We recommend that management implement additional controls and policies over period of performance. Staff who purchase items with grant funds should have additional training on period of performance requirements. Views of Responsible Officials TVCCA recognizes the validity of this finding. TVCCA is strengthening its period-of-performance controls by training all staff with purchasing authority, and finance staff, on grant deadlines, obligation definitions, and allowable spend-down periods. Internal controls will be enhanced by incorporating quarterly cutoff testing into the month-end close checklist. Additionally, cutoff testing results will be monitored quarterly as part of the quarter-end review process.

Finding Number 2019-001: Significant Deficiency in Internal Control Over Compliance ? Allocation of Shared Program Costs Criteria: In accordance with the Uniform Guidance and the State of Connecticut Office of Policy & Management Cost Standards (?OPM Cost Standards?), if a cost benefits two or more projects or activities in proportions that can be determined without undue effort or cost, the cost should be allocated to the projects or activities based on the proportional benefit received. If a cost benefits two or more projects or activities in proportions that cannot be determined because of the interrelationship of the work involved, then the costs may be allocated or transferred to benefitted projects on any reasonable documented basis. Condition: During our audit, we noted that TVCCA?s Cost Allocation Plan (CAP) does not currently provide sufficient guidance on how to estimate and allocate the costs of employees that directly benefit multiple programs or activities, when the proportional benefit received cannot be determined due to the interrelationship of the work involved. Specifically, we noted that certain Early Childhood programs that are braided by TVCCA, are currently funded by two or more funding sources. Amounts charged to each funding source for the costs of employees that work directly on these programs are based on approved budgets rather than on time and effort reporting or another reasonable basis such as number of children served. Cause: TVCCA does not currently utilize an employee time tracking system that would allow employees to record actual hours worked by program. In addition, TVCCA?s Cost Allocation Plan does not currently provide sufficient guidance on how to estimate and allocate the costs of employees that directly benefit multiple programs or activities when the proportional benefit received cannot be determined due to the interrelationship of the work involved. Effect: Additional documentation and analysis was required in order to determine that certain selected employees tested were ultimately charged to multiple programs or multiple funding sources based on the proportional benefit received. In addition, based on TVCCA?s current Cost Allocation Plan and its procedures for allocating costs of employees that directly benefit multiple programs or activities, there is a risk that shared costs may not be charged based the proportional benefit received in the future. Questioned Costs: No questioned costs were identified. Context: No questioned costs were identified. Recommendation: We recommend that TVCCA update its Cost Allocation Plan and procedures to address the allocation of costs of employees that directly benefit multiple programs or activities when the proportional benefit received cannot be determined due to the interrelationship of the work. We recommend that TVCCA consider allocating the cost of employees for its Early Childhood programs based on the number of children served or slots funded by each funding source. In addition, we also recommend that TVCCA consider requesting the ability to blend funds from its funding sources to achieve its program objectives. By blending the programs, TVCCA would not be required to allocate costs to individual funding sources based on the proportional benefit received. Views of Responsible Officials: TVCCA is currently in the process of reviewing the above finding and recommendation in order to take the necessary steps to address this finding.

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