CENTER FOR ADVOCACY FOR THE RIGHTS AND INTERESTS OF THE ELDERLY

Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Special Programs for the Aging Assistance Listing Number: 93.048 Federal Award Identification Number and Year: 90MPPG009 Award Period: June 1, 2022 – May 31, 2023 Type of Finding: Material Weakness in internal control over compliance and compliance Condition: For the fiscal year ended June 30, 2023, the organization did comply with the quarterly report filing requirements as stated per the contract with the funding agency. Criteria or specific requirement: Internal controls should be in place to provide reasonable assurance that report filing is performed timely and accurately as stipulated per the contract. Context: During the course of our audit, we were not provided with quarterly SF-425 reports for the purposes of compliance testing. We were later informed by management that these reports were not filed with the funding agency. Although we understand many of these matters were the result of the transition in the finance department, this matter highlighted insufficient internal controls over the major federal program. Effect: The lack of controls in place over major federal programs increases the risk of noncompliance not being detected and corrected on a timely basis. Cause: For the year ended June 30, 2023, management did not have controls in place to properly and timely comply with the contract requirement of the major federal program. Recommendation: We recommend management evaluate their internal controls surrounding the major federal programs to ensure compliance with the reporting requirements of their grants. Views of responsible officials and planned corrective actions: See accompanying Corrective Action Plan for the year ended June 30, 2023.

FA 2019 ? 001: Reporting Federal agency: U.S. Department of Justice (DOJ) Federal program title: Crime victim Assistance CFDA Number: 16.575 Award Period: July 1, 2016 ? June 30, 2019; October 1, 2016 ? September 30, 2019; April 1, 2018 ? September 30, 2019 Type of Finding: Significant Deficiency in Internal Control over Compliance, Non-Compliance Criteria: 2 CFR 200, Cost Principles for Nonprofit Organizations requires compliance with the provisions of allowable costs and activities. The Organization is responsible for having internal controls designed to ensure compliance with this provision. Condition: CARIE employees are charged to the federal program based on estimated budgets and time allocations. During our testing of time and effort, we reviewed employees? timesheets and found no evidence for the allocation of time based on actual results as described in Uniform Guidance Section 2 CFR 200.430. We concluded that the method for allocating an employee?s time on an entity-wide and administrative level was based on estimated budgets. Questioned Cost: None Context: We sampled the total population of employees and pay periods charged to the federal program for the year ended June 30, 2019. The sample size tested was 25 transactions, selected haphazardly, whereby we traced an employees? authorized wage and approved timesheet to the payroll register for the selected pay period. Based on our review of the timesheets for the period July 1, 2018 ? December 31, 2018, we noted that while the use of a budgeted distribution system was being utilized there was no formalized system of documentation of actual time spent on the federal programs established. Effective January 1, 2019 management implemented a time reporting system whereby all employees are required to document time and effort for each program. During our testing we found no exceptions for the period January 1, 2019 ? June 30, 2019 Cause: Section 2 CFR 200.430, referred to as time and effort reporting, requires that time distribution records must be maintained for all employees whose salary is paid in whole or in part with federal funds or is used to meet a match or cost-share requirement for a grant. Payroll allocations among grant awards cannot be based on budgeted distributions alone. Rather, allocations of salaries and wages among grant programs need to be supported by actual hours worked. If budgeted numbers are used to allocate salaries and wages among grant programs, the entity?s system of internal controls should include an after-the-fact review of the grant programs. Effect: Noncompliance to the allowable cost and activities requirements as described in both the grant awards and 2 CFR Part 200.430, Cost Principles for Nonprofit Organizations, Time and Effort Reporting may, unless the current documentation system is enhanced, potentially lead to adverse comments or concerns from any funders. Recommendation: To ensure that CARIE is in compliance with 2 CFR Part 200.430, Cost Principles for Nonprofit Organizations, Time and Effort Reporting, we recommend that management continue to use their revised internal time keeping system, whereby an employee certifies his or her time based on the actual programs he or she is assigned, and that program supervisors continue to review and certify the time and effort charged to each specific program including federal programs. Views of Responsible Officials and Planned Corrective Actions: As noted by the auditors above, this matter was address effective January 1, 2019 as a new time reporting system was implemented. See the accompanying Corrective Action Plan for additional details on the matter.

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