EIN: 237267972
UEI: F1EUGVJ8BGP6
Data as of August 26, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on February 16, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by August 16, 2026 (10 days ago).
What is a management decision? →The Organization’s internal control system failed to provide for a complete an accurate SEFA being audited. Cause: Organization staff responsible for preparation of the SEFA had significant turnover during the period under audit and short thereafter. As such, the procedures and controls necessary to prepare an accurate SEFA were not in place. Effect: The initial SEFA prepared by management of the Organization improperly reported several awards which resulted in an overstatement of expenditures. Numerous revisions to the SEFA were required for complete and accurate presentation. Questioned Costs: None Repeat finding: No Recommendations: We recommend management continue to be aware of the financial reporting requirements relating to the Organization’s SEFA and review its processes and internal controls that impact the preparation of the SEFA. Response: Management agrees with the finding.
Show full finding ▾Hide full finding ▴Preparation of Schedule of Expenditures of Federal Awards Significant Deficiency Impacted Major Programs: 19.510 U.S. Refugee Admissions Program 93.558 Temporary Assistance For Needy Families (TANF) Criteria: Proper controls over financial reporting includes the ability to prepare the schedule of expenditures of federal awards (SEFA) and accompanying notes to the SEFA in accordance with the requirements of the Uniform Guidance, section 200.510, paragraph b. Condition: The Organization’s internal control system failed to provide for a complete an accurate SEFA being audited. Cause: Organization staff responsible for preparation of the SEFA had significant turnover during the period under audit and short thereafter. As such, the procedures and controls necessary to prepare an accurate SEFA were not in place. Effect: The initial SEFA prepared by management of the Organization improperly reported several awards which resulted in an overstatement of expenditures. Numerous revisions to the SEFA were required for complete and accurate presentation. Questioned Costs: None Repeat finding: No Recommendations: We recommend management continue to be aware of the financial reporting requirements relating to the Organization’s SEFA and review its processes and internal controls that impact the preparation of the SEFA. Response: Management agrees with the finding.
Management agrees with the finding. Both myself and our controller, David Stein, are in the process of reviewing and refining SEFA-related procedures to be published in our internal accounting operations documentation. This will be completed in anticipation of future audit periods (2025 and beyond) and completed within 120 days of the date of this correspondence. The improved documentation will insulate SEFA processes from staffing levels, turnover, and the reliance on specific individuals for completion.
The Organization did not timely file their annual audit with Federal Audit Clearinghouse. Cause: Organization staff responsible for preparation of the financial statements had significant turnover during the period under audit and short thereafter. As such, the procedures and controls necessary to timely prepare accurate financial statements were not in place. Effect: The Organization’s audit report for the current fiscal period was not filed timely with the Federal Audit Clearinghouse as per the requirements of the Uniform Guidance. Questioned Costs: None Repeat finding: No Recommendations: We recommend management continue to be aware of the financial reporting requirements of the Uniform Guidance and review its processes and internal controls that impact the preparation of it’s annual financial statements. Response: Management agrees with the finding
Show full finding ▾Hide full finding ▴2024-002 Late filing of required reports Significant Deficiency Impacted Major Programs: 19.510 U.S. Refugee Admissions Program 93.558 Temporary Assistance For Needy Families (TANF) Criteria: The Uniform Guidance, section 200.507, paragraph c, subparagraph 1, states the Organization’s audit must be completed and submitted withing 30 calendar days after the Organization receives the auditor’s report or nine months after the end of the audit period (whichever is earlier) Condition: The Organization did not timely file their annual audit with Federal Audit Clearinghouse. Cause: Organization staff responsible for preparation of the financial statements had significant turnover during the period under audit and short thereafter. As such, the procedures and controls necessary to timely prepare accurate financial statements were not in place. Effect: The Organization’s audit report for the current fiscal period was not filed timely with the Federal Audit Clearinghouse as per the requirements of the Uniform Guidance. Questioned Costs: None Repeat finding: No Recommendations: We recommend management continue to be aware of the financial reporting requirements of the Uniform Guidance and review its processes and internal controls that impact the preparation of it’s annual financial statements. Response: Management agrees with the finding
Management agrees with the finding. We will expand staff participation in the audit process for future audit periods (2025 and beyond) as a guard against delays related to vacancies or turnover and to provide adequate resources to support timey filing.
FAC accepted this audit on June 12, 2024 — management decision was due December 12, 2024.
The Organization does not have an internal control system designed to provide for a complete an accurate Schedule being audited. As auditors, we were requested to assist with the preparation of the Schedule. Cause: Auditor assistance with preparation of the Schedule is not unusual as the Schedule has unique and specialized requirements and preparation is only required when the Organization meets a specified threshold of federal expenditures. Effect: The initial Schedule prepared by management of the Organization excluded two Federal awards and misclassified several awards in the schedule. Numerous revisions to the Schedule were required for complete and accurate presentation. Questioned Costs: None reported. Context: Sampling was not used. Repeat Finding from Prior Years: No. Recommendation: We recommend management be aware of the financial reporting requirements relating to the Organization’s Schedule and review its processes and internal controls that impact the preparation of the Schedule. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴Criteria: Proper controls over financial reporting includes the ability to prepare the schedule of expenditures of federal awards (Schedule) and accompanying notes to the Schedule. Condition: The Organization does not have an internal control system designed to provide for a complete an accurate Schedule being audited. As auditors, we were requested to assist with the preparation of the Schedule. Cause: Auditor assistance with preparation of the Schedule is not unusual as the Schedule has unique and specialized requirements and preparation is only required when the Organization meets a specified threshold of federal expenditures. Effect: The initial Schedule prepared by management of the Organization excluded two Federal awards and misclassified several awards in the schedule. Numerous revisions to the Schedule were required for complete and accurate presentation. Questioned Costs: None reported. Context: Sampling was not used. Repeat Finding from Prior Years: No. Recommendation: We recommend management be aware of the financial reporting requirements relating to the Organization’s Schedule and review its processes and internal controls that impact the preparation of the Schedule. Views of Responsible Officials: Management agrees with the finding.
Condition: The Organization does not have an internal control system designed to provide for a complete and accurate schedule of expenditures of federal awards being audited. As auditors, we were requested to assist with the preparation of the Schedule. Planned Corrective Action: Management is reviewing and improving internal controls over preparation of the schedule of expenditures of federal awards required by the Uniform Guidance to ensure completeness and accuracy of reporting of federal awards expended. Contact Person: Amy Carolus, Chief Financial Officer Anticipated Completion Date: December 31, 2023
Refugee case files, specifically related to the Afghan Placement and Assistance Program, lacked certain documentation required by the Cooperative Agreements. Cause: Due to the high volume of Afghan Placement and Assistance Program arrivals in a short time span, the Organization was directed by its funding agencies to focus first on the provision of services to the clients, knowing that documentation of such services may be lacking. Furthermore, due to the demands of the program, the Organization also experienced considerable turnover in program staff which led to a lack of completion and maintenance of the documentation required by the Cooperative Agreements. Effect: Refugee case files were incomplete and lacked the documentation required by the Cooperative Agreements. Questioned Costs: None reported. Context: A nonstatistical sample of 30 arrivals were tested, of which required documentation was missing within 8 of the files tested. Repeat Finding from Prior Years: No. Recommendation: We recommend that management continue to monitor and enhance its procedures and internal controls over federal award compliance to incorporate a detailed, timely review of refugee case files to ensure documentation is complete and consistent with the requirements of the Cooperative Agreements. Views of Responsible Officials: Management agrees with the finding. However, management notes that the Cooperative Agreement specific to the Afghan Placement and Assistance Program directed the Organization to focus on the provision of services and to include documentation of such activities to the extent possible. Furthermore, the Organization’s funding agencies have performed numerous monitoring reviews of the case files, including reviews specific to the Afghan Placement and Assistance Program. While the results of these reviews did note similar findings, subsequent to year-end, the Organization received written documentation that all such findings have been satisfactorily resolved and that the Organization is in compliance with the terms and conditions of the Cooperative Agreement.
Show full finding ▾Hide full finding ▴Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Furthermore, the Cooperative Agreements entered into by the Organization and its funding agencies contain documentation requirements related to refugee case files which must be maintained. Condition: Refugee case files, specifically related to the Afghan Placement and Assistance Program, lacked certain documentation required by the Cooperative Agreements. Cause: Due to the high volume of Afghan Placement and Assistance Program arrivals in a short time span, the Organization was directed by its funding agencies to focus first on the provision of services to the clients, knowing that documentation of such services may be lacking. Furthermore, due to the demands of the program, the Organization also experienced considerable turnover in program staff which led to a lack of completion and maintenance of the documentation required by the Cooperative Agreements. Effect: Refugee case files were incomplete and lacked the documentation required by the Cooperative Agreements. Questioned Costs: None reported. Context: A nonstatistical sample of 30 arrivals were tested, of which required documentation was missing within 8 of the files tested. Repeat Finding from Prior Years: No. Recommendation: We recommend that management continue to monitor and enhance its procedures and internal controls over federal award compliance to incorporate a detailed, timely review of refugee case files to ensure documentation is complete and consistent with the requirements of the Cooperative Agreements. Views of Responsible Officials: Management agrees with the finding. However, management notes that the Cooperative Agreement specific to the Afghan Placement and Assistance Program directed the Organization to focus on the provision of services and to include documentation of such activities to the extent possible. Furthermore, the Organization’s funding agencies have performed numerous monitoring reviews of the case files, including reviews specific to the Afghan Placement and Assistance Program. While the results of these reviews did note similar findings, subsequent to year-end, the Organization received written documentation that all such findings have been satisfactorily resolved and that the Organization is in compliance with the terms and conditions of the Cooperative Agreement.
Condition: Refugee case files, specifically related to the Afghan Placement and Assistance Program, lacked certain documentation required by the Cooperative Agreements. Planned Corrective Action Management is reviewing and improving internal controls over review of refugee case file documentation. The Cooperative Agreement specific to the Afghan Placement and Assistance Program directed the Organization to focus on the provision of services and to include documentation of such activities to the extent possible. Furthermore, the Organization’s funding agencies have performed numerous monitoring reviews of the case files, including reviews specific to the Afghan Placement and Assistance Program. While the results of these reviews did note similar findings, subsequent to year-end, the Organization received written documentation that all such findings have satisfactorily been resolved and that the Organization is in compliance with the terms and conditions of the Cooperative Agreement. Contact Person: Amy Carolus, Chief Financial Officer Anticipated Completion Date: December 31, 2023
FAC accepted this audit on July 6, 2022 — management decision was due January 6, 2023.
Costs billed to the funding agency for rent, janitorial, telephone and office supplies/postage/printing exceeded amounts determined by supporting shared cost allocation calculations. Also, certain salaries billed to the grant award exceeded amounts recorded as expenses in the program. Questioned Costs: $25,610 Cause: Lutheran Family Services of Nebraska, Inc. has internal control processes in place to allocate shared costs to various programs. Certain costs billed to the funding agency appeared to have been billed in accordance with amounts budgeted for the grant rather than based upon actual amounts incurred or shared allocated to the program. Effect: Per 45 CFR 75.371, If a non-Federal entity fails to comply with Federal statutes, regulations, or the terms and conditions of a Federal award, the HHS awarding agency or pass-through entity may impose additional conditions, as described in ? 75.207. If the HHS awarding agency or pass-through entity determines that noncompliance cannot be remedied by imposing additional conditions, the HHS awarding agency or pass-through entity may take one or more of the following actions, as appropriate in the circumstances: (a) Temporarily withhold cash payments pending correction of the deficiency by the non-Federal entity or more severe enforcement action by the HHS awarding agency or pass-through entity. (b) Disallow (that is, deny both use of funds and any applicable matching credit for) all or part of the cost of the activity or action not in compliance. (c) Wholly or partly suspend (suspension of award activities) or terminate the Federal award. (d) Initiate suspension or debarment proceedings as authorized under 2 CFR part 180 and HHS awarding agency regulations at 2 CFR part 376 (or in the case of a pass-through entity, recommend such a proceeding be initiated by a HHS awarding agency). (e) Withhold further Federal awards for the project or program. (f) Take other remedies that may be legally available. Context: Certain agency wide costs, including rent, janitorial services, insurance, telephone and certain other supplies and office expenses are allocated to various programs based upon time spent. The total of amounts billed exceeded allocated totals recognized as expenses in the program in the amount of $23,481. Salaries and related benefits billed to the program exceeded amounts recorded in the general ledger for March 2021 amounted to $2,129. Recommendation: We recommend management review its shared cost allocation process to ensure that amounts allocated are appropriately recognized in the general ledger for each program and amounts billed to various grant awards are adequately supported and are consistent with amounts allocated to grant programs. Views of Responsible Officials: Management concurs with the finding. See Corrective Action Plan.
Show full finding ▾Hide full finding ▴Item 2021-003 Significant Deficiency Identification of the Federal Program: Section 223 Demonstration Programs to Improve Community Mental Health Federal Assistance Listing - 93.829 Criteria or Specific Requirement: The program is subject to the cost principles as applicable in Title 45 CFR Part 75, Uniform Administrative Requirements, Cost Principles and Audit Requirements for HHS Awards (Uniform Guidance). 45 CFR 75.403 indicates costs must be necessary and reasonable for the performance of the Federal award and be adequately documented. Condition: Costs billed to the funding agency for rent, janitorial, telephone and office supplies/postage/printing exceeded amounts determined by supporting shared cost allocation calculations. Also, certain salaries billed to the grant award exceeded amounts recorded as expenses in the program. Questioned Costs: $25,610 Cause: Lutheran Family Services of Nebraska, Inc. has internal control processes in place to allocate shared costs to various programs. Certain costs billed to the funding agency appeared to have been billed in accordance with amounts budgeted for the grant rather than based upon actual amounts incurred or shared allocated to the program. Effect: Per 45 CFR 75.371, If a non-Federal entity fails to comply with Federal statutes, regulations, or the terms and conditions of a Federal award, the HHS awarding agency or pass-through entity may impose additional conditions, as described in ? 75.207. If the HHS awarding agency or pass-through entity determines that noncompliance cannot be remedied by imposing additional conditions, the HHS awarding agency or pass-through entity may take one or more of the following actions, as appropriate in the circumstances: (a) Temporarily withhold cash payments pending correction of the deficiency by the non-Federal entity or more severe enforcement action by the HHS awarding agency or pass-through entity. (b) Disallow (that is, deny both use of funds and any applicable matching credit for) all or part of the cost of the activity or action not in compliance. (c) Wholly or partly suspend (suspension of award activities) or terminate the Federal award. (d) Initiate suspension or debarment proceedings as authorized under 2 CFR part 180 and HHS awarding agency regulations at 2 CFR part 376 (or in the case of a pass-through entity, recommend such a proceeding be initiated by a HHS awarding agency). (e) Withhold further Federal awards for the project or program. (f) Take other remedies that may be legally available. Context: Certain agency wide costs, including rent, janitorial services, insurance, telephone and certain other supplies and office expenses are allocated to various programs based upon time spent. The total of amounts billed exceeded allocated totals recognized as expenses in the program in the amount of $23,481. Salaries and related benefits billed to the program exceeded amounts recorded in the general ledger for March 2021 amounted to $2,129. Recommendation: We recommend management review its shared cost allocation process to ensure that amounts allocated are appropriately recognized in the general ledger for each program and amounts billed to various grant awards are adequately supported and are consistent with amounts allocated to grant programs. Views of Responsible Officials: Management concurs with the finding. See Corrective Action Plan.
Item 2021-003 Condition: Costs billed to the funding agency for rent, janitorial, telephone and office supplies/postage/printing exceeded amounts determined by supporting shared cost allocation calculations. Planned Corrective Action: Management has implemented an updated allocation process and controls to ensure that amounts recorded in the general ledger for each program are consistent with this methodology. As well, a formalized internal review has been put in place to ensure accurate amounts are billed to federal programs and can be properly and adequately supported. Contact Person: Amy Carolus, Chief Financial Officer Anticipated Completion Date: February 1, 2022
2020-002
Costs billed to the funding agency exceeded amounts charged to the program in the general ledger for direct costs and amounts determined by supporting shared cost allocation calculations. Questioned Costs: $47,344 Cause: Lutheran Family Services of Nebraska, Inc. has internal control processes in place to allocate shared costs to various programs. Certain costs billed to the funding agency appeared to have been billed in accordance with amounts budgeted for the grant rather than based upon actual amounts incurred or shared costs allocated to the program. Effect: Per 45 CFR 75.371, If a non-Federal entity fails to comply with Federal statutes, regulations, or the terms and conditions of a Federal award, the HHS awarding agency or pass-through entity may impose additional conditions, as described in ? 75.207. If the HHS awarding agency or pass-through entity determines that noncompliance cannot be remedied by imposing additional conditions, the HHS awarding agency or pass-through entity may take one or more of the following actions, as appropriate in the circumstances: (a) Temporarily withhold cash payments pending correction of the deficiency by the non-Federal entity or more severe enforcement action by the HHS awarding agency or pass-through entity. (b) Disallow (that is, deny both use of funds and any applicable matching credit for) all or part of the cost of the activity or action not in compliance. (c) Wholly or partly suspend (suspension of award activities) or terminate the Federal award. (d) Initiate suspension or debarment proceedings as authorized under 2 CFR part 180 and HHS awarding agency regulations at 2 CFR part 376 (or in the case of a pass-through entity, recommend such a proceeding be initiated by a HHS awarding agency). (e) Withhold further Federal awards for the project or program. (f) Take other remedies that may be legally available. Context: Certain agency wide costs, including rent, janitorial services, insurance, telephone and certain other supplies and office expenses are allocated to various programs based upon time spent. The total of amounts billed exceeded allocated totals recognized as expenses in the program in the amount of $13,790. Salaries, related benefits and other direct costs billed to the program exceeded amounts recorded in the general ledger amounted to $33,554. Recommendation: We recommend management review its shared cost allocation process to ensure that amounts allocated are appropriately recognized in the general ledger for each program and amounts billed to various grant awards are adequately supported and are consistent with amounts allocated to grant programs. Views of Responsible Officials: Management concurs with the finding. See Corrective Action Plan.
Show full finding ▾Hide full finding ▴Item 2021-004 Significant Deficiency Identification of the Federal Program: Temporary Assistance for Needy Families Federal Assistance Listing - 93.558 Criteria or Specific Requirement: The program is subject to the cost principles as applicable in Title 45 CFR Part 75, Uniform Administrative Requirements, Cost Principles and Audit Requirements for HHS Awards (Uniform Guidance). 45 CFR 75.403 indicates costs must be necessary and reasonable for the performance of the Federal award and be adequately documented. Condition: Costs billed to the funding agency exceeded amounts charged to the program in the general ledger for direct costs and amounts determined by supporting shared cost allocation calculations. Questioned Costs: $47,344 Cause: Lutheran Family Services of Nebraska, Inc. has internal control processes in place to allocate shared costs to various programs. Certain costs billed to the funding agency appeared to have been billed in accordance with amounts budgeted for the grant rather than based upon actual amounts incurred or shared costs allocated to the program. Effect: Per 45 CFR 75.371, If a non-Federal entity fails to comply with Federal statutes, regulations, or the terms and conditions of a Federal award, the HHS awarding agency or pass-through entity may impose additional conditions, as described in ? 75.207. If the HHS awarding agency or pass-through entity determines that noncompliance cannot be remedied by imposing additional conditions, the HHS awarding agency or pass-through entity may take one or more of the following actions, as appropriate in the circumstances: (a) Temporarily withhold cash payments pending correction of the deficiency by the non-Federal entity or more severe enforcement action by the HHS awarding agency or pass-through entity. (b) Disallow (that is, deny both use of funds and any applicable matching credit for) all or part of the cost of the activity or action not in compliance. (c) Wholly or partly suspend (suspension of award activities) or terminate the Federal award. (d) Initiate suspension or debarment proceedings as authorized under 2 CFR part 180 and HHS awarding agency regulations at 2 CFR part 376 (or in the case of a pass-through entity, recommend such a proceeding be initiated by a HHS awarding agency). (e) Withhold further Federal awards for the project or program. (f) Take other remedies that may be legally available. Context: Certain agency wide costs, including rent, janitorial services, insurance, telephone and certain other supplies and office expenses are allocated to various programs based upon time spent. The total of amounts billed exceeded allocated totals recognized as expenses in the program in the amount of $13,790. Salaries, related benefits and other direct costs billed to the program exceeded amounts recorded in the general ledger amounted to $33,554. Recommendation: We recommend management review its shared cost allocation process to ensure that amounts allocated are appropriately recognized in the general ledger for each program and amounts billed to various grant awards are adequately supported and are consistent with amounts allocated to grant programs. Views of Responsible Officials: Management concurs with the finding. See Corrective Action Plan.
Item 2021-004 Condition: Costs billed to the funding agency for rent, janitorial, telephone and office supplies/postage/printing exceeded amounts determined by supporting shared cost allocation calculations. Planned Corrective Action: Management has implemented an updated allocation process and controls to ensure that amounts recorded in the general ledger for each program are consistent with this methodology. As well, a formalized internal review has been put in place to ensure accurate amounts are billed to federal programs and can be properly and adequately supported. Contact Person: Amy Carolus, Chief Financial Officer Anticipated Completion Date: February 1, 2022
Eligibility determinations completed were not supported with appropriate information to verify income levels were below 200 percent of the Federal poverty level. Questioned Costs: $0 Cause: Eligibility determinations were made using an intake form, but amounts included on the intake form by applicants were not verified to supporting information to ensure income was under the 200% Federal poverty level. Effect: Benefits were provided to an ineligible recipient whose income was in excess of 200% percent of the Federal poverty level. Other benefits were provided to other recipients without obtaining documentation of their income levels. Context: Of the 12 individuals selected for testing of eligibility determinations, one individual had income levels exceeding 200% of the Federal poverty level. Two of other individuals tested did not have documentation in their files to verify income levels provided by applicants on the intake form. Proper verification of income levels would include, but not be limited to, the following: review of pay stubs, verification of employment and pay with employer, review of income tax returns, or bank statement details for evidence of employment income deposited to an account. Recommendation: We recommend management review its controls and processes over eligibility determinations being made for beneficiaries under Federal awards to ensure that information provided by applicants is complete and accurate so determinations are appropriate and Federal awards are properly administered. Views of Responsible Officials: Management concurs with the finding. See Corrective Action Plan.
Show full finding ▾Hide full finding ▴Item 2021-005 Significant Deficiency Identification of the Federal Program: Temporary Assistance for Needy Families Federal Assistance Listing - 93.558 Criteria or Specific Requirement: Funding will be awarded to organizations to implement Fatherhood Initiatives programs serving Temporary Assistance for Needy Families (TANF) eligible, low income, non-custodial, unemployed and under-employed fathers with income below 200 percent of the federal poverty level (FPL). Condition: Eligibility determinations completed were not supported with appropriate information to verify income levels were below 200 percent of the Federal poverty level. Questioned Costs: $0 Cause: Eligibility determinations were made using an intake form, but amounts included on the intake form by applicants were not verified to supporting information to ensure income was under the 200% Federal poverty level. Effect: Benefits were provided to an ineligible recipient whose income was in excess of 200% percent of the Federal poverty level. Other benefits were provided to other recipients without obtaining documentation of their income levels. Context: Of the 12 individuals selected for testing of eligibility determinations, one individual had income levels exceeding 200% of the Federal poverty level. Two of other individuals tested did not have documentation in their files to verify income levels provided by applicants on the intake form. Proper verification of income levels would include, but not be limited to, the following: review of pay stubs, verification of employment and pay with employer, review of income tax returns, or bank statement details for evidence of employment income deposited to an account. Recommendation: We recommend management review its controls and processes over eligibility determinations being made for beneficiaries under Federal awards to ensure that information provided by applicants is complete and accurate so determinations are appropriate and Federal awards are properly administered. Views of Responsible Officials: Management concurs with the finding. See Corrective Action Plan.
Item 2021-005 Condition: Eligibility determinations completed were not supported with appropriate information to verify income levels were below 200 percent of the Federal poverty level. Planned Corrective Action: Management is reviewing and improving internal controls over eligibility determinations to ensure proper documentation is being maintained for each applicant to ensure appropriate determinations are made before providing funds to beneficiaries. Contact Person: Amy Carolus, Chief Financial Officer Anticipated Completion Date: December 31, 2022
FAC accepted this audit on March 30, 2022 — management decision was due September 30, 2022.
Costs billed to the funding agency for rent, janitorial, telephone and office supplies/postage/printing exceeded amounts determined by supporting shared cost allocation calculations. Questioned Costs: $31,143 Cause: Lutheran Family Services of Nebraska, Inc. has internal control processes in place to allocate shared costs to various programs. The process was not operating effectively during the year. Costs billed to the funding agency appeared to have been billed in accordance with amounts budgeted for the grant rather than based upon actual amounts incurred or allocated to the program. Effect: Per 45 CFR 75.371, If a non-Federal entity fails to comply with Federal statutes, regulations, or the terms and conditions of a Federal award, the HHS awarding agency or pass-through entity may impose additional conditions, as described in ? 75.207. If the HHS awarding agency or pass-through entity determines that noncompliance cannot be remedied by imposing additional conditions, the HHS awarding agency or pass-through entity may take one or more of the following actions, as appropriate in the circumstances: (a) Temporarily withhold cash payments pending correction of the deficiency by the non-Federal entity or more severe enforcement action by the HHS awarding agency or pass-through entity. (b) Disallow (that is, deny both use of funds and any applicable matching credit for) all or part of the cost of the activity or action not in compliance. (c) Wholly or partly suspend (suspension of award activities) or terminate the Federal award. (d) Initiate suspension or debarment proceedings as authorized under 2 CFR part 180 and HHS awarding agency regulations at 2 CFR part 376 (or in the case of a pass-through entity, recommend such a proceeding be initiated by a HHS awarding agency). (e) Withhold further Federal awards for the project or program. (f) Take other remedies that may be legally available. Context: Certain agency wide costs, including rent, janitorial services, insurance, telephone and certain other supplies and office expenses are allocated to various programs based upon time spent. Recommendation: We recommend management review its shared cost allocation process to ensure that amounts allocated are appropriately recognized in the general ledger for each program and amounts billed to various grant awards are adequately supported. Views of Responsible Officials: Management concurs with the finding. See Corrective Action Plan.
Show full finding ▾Hide full finding ▴Item 2020-002 Significant Deficiency Identification of the Federal Program: Section 223 Demonstration Programs to Improve Community Mental Health Federal Assistance Listing - 93.829 Criteria or Specific Requirement: The program is subject to the cost principles as applicable in Title 45 CFR Part 75, Uniform Administrative Requirements, Cost Principles and Audit Requirements for HHS Awards (Uniform Guidance). 45 CFR 75.403 indicates costs must be necessary and reasonable for the performance of the Federal award and be adequately documented. Condition: Costs billed to the funding agency for rent, janitorial, telephone and office supplies/postage/printing exceeded amounts determined by supporting shared cost allocation calculations. Questioned Costs: $31,143 Cause: Lutheran Family Services of Nebraska, Inc. has internal control processes in place to allocate shared costs to various programs. The process was not operating effectively during the year. Costs billed to the funding agency appeared to have been billed in accordance with amounts budgeted for the grant rather than based upon actual amounts incurred or allocated to the program. Effect: Per 45 CFR 75.371, If a non-Federal entity fails to comply with Federal statutes, regulations, or the terms and conditions of a Federal award, the HHS awarding agency or pass-through entity may impose additional conditions, as described in ? 75.207. If the HHS awarding agency or pass-through entity determines that noncompliance cannot be remedied by imposing additional conditions, the HHS awarding agency or pass-through entity may take one or more of the following actions, as appropriate in the circumstances: (a) Temporarily withhold cash payments pending correction of the deficiency by the non-Federal entity or more severe enforcement action by the HHS awarding agency or pass-through entity. (b) Disallow (that is, deny both use of funds and any applicable matching credit for) all or part of the cost of the activity or action not in compliance. (c) Wholly or partly suspend (suspension of award activities) or terminate the Federal award. (d) Initiate suspension or debarment proceedings as authorized under 2 CFR part 180 and HHS awarding agency regulations at 2 CFR part 376 (or in the case of a pass-through entity, recommend such a proceeding be initiated by a HHS awarding agency). (e) Withhold further Federal awards for the project or program. (f) Take other remedies that may be legally available. Context: Certain agency wide costs, including rent, janitorial services, insurance, telephone and certain other supplies and office expenses are allocated to various programs based upon time spent. Recommendation: We recommend management review its shared cost allocation process to ensure that amounts allocated are appropriately recognized in the general ledger for each program and amounts billed to various grant awards are adequately supported. Views of Responsible Officials: Management concurs with the finding. See Corrective Action Plan.
Item 2020-002 Condition: Costs billed to the funding agency for rent, janitorial, telephone and office supplies/postage/printing exceeded amounts determined by supporting shared cost allocation calculations. Planned Corrective Action: Management has implemented an updated allocation process and controls to ensure that amounts recorded in the general ledger for each program are consistent with this methodology. As well, a formalized internal review has been put in place to ensure accurate amounts are billed to federal programs and can be properly and adequately supported. Contact Person: Amy Carolus, Chief Financial Officer Anticipated Completion Date: February 1, 2022
Certain payroll billed to the funding agency during the grant period were also included in payroll costs paid with the PPP loan. Questioned Costs: $34,534 Cause: The grant period started in May 2020 and payroll costs related to individuals carrying out the grant activities were billed to the grant award without giving consideration of amounts paid with the PPP loan. Effect: Per 45 CFR 75.371, If a non-Federal entity fails to comply with Federal statutes, regulations, or the terms and conditions of a Federal award, the HHS awarding agency or pass-through entity may impose additional conditions, as described in ? 75.207. If the HHS awarding agency or pass-through entity determines that noncompliance cannot be remedied by imposing additional conditions, the HHS awarding agency or pass-through entity may take one or more of the following actions, as appropriate in the circumstances: (a) Temporarily withhold cash payments pending correction of the deficiency by the non-Federal entity or more severe enforcement action by the HHS awarding agency or pass-through entity. (b) Disallow (that is, deny both use of funds and any applicable matching credit for) all or part of the cost of the activity or action not in compliance. (c) Wholly or partly suspend (suspension of award activities) or terminate the Federal award. (d) Initiate suspension or debarment proceedings as authorized under 2 CFR part 180 and HHS awarding agency regulations at 2 CFR part 376 (or in the case of a pass-through entity, recommend such a proceeding be initiated by a HHS awarding agency). (e) Withhold further Federal awards for the project or program. (f) Take other remedies that may be legally available. Context: Payroll paid with the PPP loan covered payroll periods from April 2020 through July 2020. Certain amounts billed under the grant for the months of May 2020 through July 2020 were also paid under the PPP loan resulting in the Federal government paying for the same expenditures twice. Recommendation: We recommend management review its processes and controls over the accounting and reporting for Federal grant activities to ensure that amounts are only applied once to the appropriate Federal or other grant. Views of Responsible Officials: Management concurs with the finding. See Corrective Action Plan.
Show full finding ▾Hide full finding ▴Item 2020-003 Identification of the Federal Program Section 223 Demonstration Programs to Improve Community Mental Health Federal Assistance Listing - 93.829 Criteria or Specific Requirement: Office of Management and Budget (OMB) Memorandum M 20-26 states that payroll costs paid with the Paycheck Protection Program (PPP) loans or any other Federal CARES Act programs must not also be charged to current Federal awards as it would result in the Federal Government paying for the same expenditures twice. Awarding agencies must require recipients to maintain appropriate records and cost documentation as required by 2 CFR 200.302 ? Financial Management and 2 CFR 200.333 ? Retention of Requirement of Records to substantiate the charging of any salaries and other project activities costs related to interruption of operations or services. Condition: Certain payroll billed to the funding agency during the grant period were also included in payroll costs paid with the PPP loan. Questioned Costs: $34,534 Cause: The grant period started in May 2020 and payroll costs related to individuals carrying out the grant activities were billed to the grant award without giving consideration of amounts paid with the PPP loan. Effect: Per 45 CFR 75.371, If a non-Federal entity fails to comply with Federal statutes, regulations, or the terms and conditions of a Federal award, the HHS awarding agency or pass-through entity may impose additional conditions, as described in ? 75.207. If the HHS awarding agency or pass-through entity determines that noncompliance cannot be remedied by imposing additional conditions, the HHS awarding agency or pass-through entity may take one or more of the following actions, as appropriate in the circumstances: (a) Temporarily withhold cash payments pending correction of the deficiency by the non-Federal entity or more severe enforcement action by the HHS awarding agency or pass-through entity. (b) Disallow (that is, deny both use of funds and any applicable matching credit for) all or part of the cost of the activity or action not in compliance. (c) Wholly or partly suspend (suspension of award activities) or terminate the Federal award. (d) Initiate suspension or debarment proceedings as authorized under 2 CFR part 180 and HHS awarding agency regulations at 2 CFR part 376 (or in the case of a pass-through entity, recommend such a proceeding be initiated by a HHS awarding agency). (e) Withhold further Federal awards for the project or program. (f) Take other remedies that may be legally available. Context: Payroll paid with the PPP loan covered payroll periods from April 2020 through July 2020. Certain amounts billed under the grant for the months of May 2020 through July 2020 were also paid under the PPP loan resulting in the Federal government paying for the same expenditures twice. Recommendation: We recommend management review its processes and controls over the accounting and reporting for Federal grant activities to ensure that amounts are only applied once to the appropriate Federal or other grant. Views of Responsible Officials: Management concurs with the finding. See Corrective Action Plan.
Item 2020-003 Condition: Certain payroll costs billed to the funding agency during the grant period were also included in payroll costs paid with the PPP loan. Planned Corrective Action: Management has implemented a formalized internal review to ensure accurate amounts are billed to federal programs and can be properly and adequately supported. Contact Person: Amy Carolus, Chief Financial Officer Anticipated Completion Date: February 1, 2022
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