The Children's Home of Poughkeepsie, New York, Inc.

Financial Reporting Information on Federal Program: Unaccompanied Alien Children (Assistance Lising No. 93.676) provided by the Department of Health and Human Services. Criteria: Compliance under Unaccompanied Alien Children (Assistance Listing No. 93.676): Financial Reporting Requirements, submission of SF-425, Federal Financial Report. Condition: During our testing of compliance with the submission of the SF-425, Federal Financial Report, we noted that three of eleven required quarterly reports were not filed by the required due date. In addition, the annual submission for long-term foster care was filed after the required due date. Questioned Cost: None Cause: The Home did not have a procedure in place to ensure that required reports were completed and submitted by the required due dates. Effect: Three submissions of the quarterly, and one annual submission of annual Federal Financial Report (SF-425) were not filed by the required deadlines. Perspective Information: The Home has been operating at reduced staffing levels and has had turnover in finance positions which has disrupted normal operations. Repeat Finding: Yes Recommendation: We recommend the Home implement a procedure or checklist to ensure that the required reports are completed and submitted by the required due dates. Views of the Responsible Officials and Planned Corrective Actions: CHP underwent a transition in Fiscal leadership during this fiscal year. In addition, CHP was assigned a new Grant Management Specialist that rejected FFR reports for missing information that was not previously provided. Corrections were made following the rejections and the resubmission dates were updated with the latter date. CHP will continue to utilize a recurring calendar reminder.

Compliance with Uniform Guidance - Procurement Suspension and Debarment Information on Federal Program: Unaccompanied Alien Children (Assistance Listing No. 93.676) provided by the Department of Health and Human Services. Criteria: 2 CFR Sections 200.212, 200.318(h), and 180.300 and 48 CFR Section 52.209-6 state that a non-Federal entity must review that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded from participation in federal award programs. Condition: During our testing for procurement compliance, it was determined that the Home did not verify that vendors charged to the major program are not debarred, suspended, or otherwise excluded from participation in federal award programs. Questioned Cost: None Cause: The Home was not aware of the requirement to review an entity’s status. Effect: The Home is not in compliance with 2 CFR Sections 200.212, 200.318(h), and 180.300 and 48 CFR Section 52.209-6. As a result, the Home could enter into covered transactions with entities that are debarred, suspended, or otherwise excluded from participation in federal award programs. Perspective Information: Vendors in excess of the $25,000 threshold were reviewed to determine if they are debarred, suspended, or otherwise excluded from participation in federal award programs. None were noted to be ineligible for participation. Repeat Finding: Yes Recommendation: We recommend the Home review and document the verification that vendors are not debarred, suspended, or otherwise excluded from participation in federal award programs. Views of the Responsible Officials and Planned Corrective Actions: This item was included in the 6/30/22 Report on Compliance for Major Federal Programs which was finalized in February 2023. The G/L Vendor List was found to contain many inactive vendors and was modified. Beginning in October 2023, management began sending the vendor List to EPStaffCheck on a monthly basis. Each vendor is run through OIG (Office of Inspector General for Excluded Individuals/Entities); OIG_Most_Wanted (Fugitives}; SAM (System for Award Management for excluded parties); SON.Office of Foreign Assets Control (Specially Designated Nationals) and NY _Medicaid (Exclusion List).

Financial and Performance Reporting Information on Federal Program: Unaccompanied Alien Children (Assistance Lising No. 93.676) provided by the Department of Health and Human Services. Criteria: Compliance under Unaccompanied Alien Children (Assistance Listing No. 93.676): Financial Reporting Requirements, submission of SF-425, Federal Financial Report. Condition: During our testing of compliance with the submission of the SF-425, Federal Financial Report, we noted that seven of eight required quarterly reports were not filed by the required due date. In addition, the annual submission for long-term foster care was filed after the required due date. Questioned Cost: None Cause: The Home did not have a procedure in place to ensure that required reports were completed and submitted by the required due dates. Effect: Seven submissions of the quarterly, and one annual submission of Federal Financial Report (SF-425) were not filed by the required deadlines. Perspective Information: The Home has been operating at reduced staffing levels and has had turnover in finance positions which has disrupted normal operations. Repeat Finding: Yes Recommendation: We recommend the Home implement a procedure or checklist to ensure that the required reports are completed and submitted by the required due dates. Views of the Responsible Officials and Planned Corrective Actions: CHP underwent a transition in Fiscal leadership during this fiscal year. In addition, CHP was assigned a new Grant Management Specialist that rejected FFR reports for missing information that was not previously provided. Corrections were made following the rejections and the resubmission dates were updated with the latter date. CHP will continue to utilize a recurring calendar reminder.

Allowable Costs Information on Federal Program: Unaccompanied Alien Children (Assistance Lising No. 93.676) provided by the Department of Health and Human Services. Criteria: 2 CFR Part 200 Section 200.403(e) states that in order for costs to be allowable under federal awards they must be determined in accordance with generally accepted accounting principles (GAAP). 2 CFR Part 200 Section 200.403(h) states that costs must be incurred during the budget period. Condition: During our testing of compliance related to allowable costs for award 90ZU041701 it was determined that costs related to the previous award (90ZU027903) period were not claimed in the amount of $349,082. Questioned Cost: None Cause: The Home did not have a procedure in place to reconcile and review that claims included all allowable expenses and that all claims were made prior to the close out of the award period. Effect: Award 90ZU027903 was under-claimed by $349,082 based on allowable costs. Perspective Information: Upon commencing employment, the new Chief Financial Officer implemented a process to review allowable costs on a weekly basis, with a year-todate review done weekly in addition. Repeat Finding: No Recommendation: We recommend the Home implement a procedure to review and reconcile that all claims for each individual award are submitted. Views of the Responsible Officials and Planned Corrective Actions: With the transition to a new CFO, allowable costs are now reviewed on a weekly basis, in addition to a year-todate review being done weekly, by award.

Compliance with Uniform Guidance ? Procurement Suspension and Debarment Information on Federal Program: Unaccompanied Alien Children (Assistance Listing No. 93.676) provided by the Department of Health and Human Services. Criteria: 2 CFR Sections 200.212, 200.318(h), and 180.300 and 48 CFR Section 52.209-6 state that a non-Federal entity must review that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded from participation in federal award programs. Condition: During our testing for procurement compliance, it was determined that the Home did not verify that vendors charged to the major program are not debarred, suspended, or otherwise excluded from participation in federal award programs. Questioned Cost: None Cause: The Home was not aware of the requirement to review an entity?s status. Effect: The Home is not in compliance with 2 CFR Sections 200.212, 200.318(h), and 180.300 and 48 CFR Section 52.209-6. As a result, the Home could enter into covered transactions with entities that are debarred, suspended, or otherwise excluded from participation in federal award programs. Perspective Information: Vendors in excess of the $25,000 threshold were reviewed to determine if they are debarred, suspended, or otherwise excluded from participation in federal award programs. None were noted to be ineligible for participation. Repeat Finding: Yes Recommendation: We recommend the Home review and document the verification that vendors are not debarred, suspended, or otherwise excluded from participation in federal award programs. Views of the Responsible Officials and Planned Corrective Actions: The Home will revise its procurement policy to include a semi-annual review of the vendors eligible to participate in the federal award programs.

Financial and Performance Reporting Information on Federal Program: Unaccompanied Alien Children (Assistance Lising No. 93.676) provided by the Department of Health and Human Services. Criteria: Compliance under Unaccompanied Alien Children (Assistance Listing No. 93.676): Financial Reporting Requirements, submission of SF-425, Federal Financial Report. Condition: During our testing of compliance with the submission of the SF-425, Federal Financial Report, we noted that the quarterly report due April 30, 2022 was submitted June 6, 2022 and the quarterly report due September 30, 2022 has not been submitted. In addition, the annual submission due April 30, 2022 was submitted September 1, 2022. Questioned Cost: None Cause: The Home did not have a procedure in place to ensure that required reports were completed and submitted by the required due dates. Effect: Two submissions of the quarterly, and one annual submission of Federal Financial Report (SF-425) were not filed by the required deadlines. Perspective Information: The COVID-19 pandemic has resulted in the Home operating at reduced staffing levels and in a remote capacity which has disrupted normal operations. Additionally, the Fiscal Director position was vacant from January 2022 through April 2022. Repeat Finding: Yes Recommendation: We recommend the Home implement a procedure or checklist to ensure that the required reports are completed and submitted by the required due dates. Views of the Responsible Officials and Planned Corrective Actions: A recurring calendar reminder will be set in order to remind the Home of the due dates to submit the Federal Financial Reports.

Compliance with Uniform Guidance ? Procurement Suspension and Debarment Information on Federal Program: Unaccompanied Alien Children (CFDA No. 93.676) provided by the Department of Health and Human Services. Criteria: 2 CFR Sections 200.212, 200.318(h), and 180.300 and 48 CFR Section 52.209-6 state that a non-Federal entity must review that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded from participation in federal award programs. Condition: During our testing for procurement compliance, it was determined that the Home did not verify that vendors charged to the major program are not debarred, suspended, or otherwise excluded from participation in federal award programs. Questioned Cost: None Cause: The Home was not aware of the requirement to review an entity?s status. Effect: The Home is not in compliance with 2 CFR Sections 200.212, 200.318(h), and 180.300 and 48 CFR Section 52.209-6. As a result, the Home could enter into covered transactions with entities that are debarred, suspended, or otherwise excluded from participation in federal award programs. Context: Vendors in excess of the $25,000 threshold were reviewed to determine if they are debarred, suspended, or otherwise excluded from participation in federal award programs. None were noted to be ineligible for participation. Repeat Finding: No Recommendation: We recommend the Home review and document the verification that vendors are not debarred, suspended, or otherwise excluded from participation in federal award programs. Views of the Responsible Officials and Planned Corrective Actions: The Home will revise its procurement policy to include a semi-annual review of the vendors eligible to participate in the federal award programs.

Financial and Performance Reporting Information on Federal Program: Unaccompanied Alien Children (CFDA No. 93.676) provided by the Department of Health and Human Services. Criteria: Compliance under Unaccompanied Alien Children (CFDA No. 93.676): Financial Reporting Requirements, submission of SF-425, Federal Financial Report. Condition: During our testing of compliance with the submission of the SF-425, Federal Financial Report, we noted that the quarterly report due January 30, 2021 was submitted February 8, 2021 and the quarterly report due July 30, 2021 was submitted August 10, 2021. Questioned Cost: None Cause: The Home did not have a procedure in place to ensure that required reports were completed and submitted by the required due dates. Effect: Two submissions of the quarterly Federal Financial Report (SF-425) were not filed by the required deadline. Context: The COVID-19 pandemic has resulted in the Home operating at reduced staffing levels and in a remote capacity which has disrupted normal operations. Repeat Finding: No Recommendation: We recommend the Home implement a procedure or checklist to ensure that the required reports are completed and submitted by the required due dates. Views of the Responsible Officials and Planned Corrective Actions: A recurring calendar reminder will be set in order to remind the Home of the due dates to submit the Federal Financial Reports.

Section III: Federal Award Findings and Questioned Costs Findings and questioned costs related to Federal awards which are required to be reported in accordance with 2 CFR.516(a): 2020-001 Compliance with Uniform Guidance - Procurement Information on Federal Program: Unaccompanied Alien Children (CFDA No. 93.676) provided by the Department of Health and Human Services. Condition: During our testing for procurement compliance, it was determined that the Home did not retain the documentation related to application of the Home?s procurement policy. Questioned Cost: None Criteria: Section 200.318(i) of the Uniform Guidance states that a non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but, are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Cause: Current purchasing policy does not contain specific documentation retention guidelines to satisfy procurement compliance requirements as stated in the Uniform Guidance. Effect: The Home is not in compliance with 2 CFR Section 200.218. As a result the Home be overpaying for goods and services. Context: A of sample of three purchases from a population of 24 items were tested for procurement compliance. Only one item selected for testing had documentation supporting the procurement process. Repeat Finding: No Recommendation: We recommend the Home?s purchasing procedure manual be updated for to align with the procurement standards related to the Uniform Guidance. Specifically, the policy should be updated to address requirements for micro-purchases (purchases less than $10,000) and small purchases (greater than $10,000 and less than $250,000) Views of the Responsible Officials and Planned Corrective Actions: Management agrees with the finding and in response has implemented a revised purchasing policy that is in compliance with 2 CFR Section 200.218.