CHRISTOPHER HOUSE

Assistance Listing Number, Federal Agency, and Program Name - 93.600, U.S. Department of Health and Human Services, Head Start Cluster Federal Award Identification Number and Year - 2021-2022 Pass-through Entity - Region V Office for Children and Families, City of Chicago Department of Family Support Services Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - No Criteria - The Organization is required to file form SF-429 Real Property Status Report and SF-429-A General Reporting annually when the Organization has real property with a federal interest. Condition - The SF-429 and SF-429-A reports were not filed for the year 2021. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The SF-429 and SF-429-A reports were not filed for the year 2021. Cause and Effect - The Organization experienced internal turnover in the finance department during the year, which was responsible for completing the annual report submission. As a result, the deadline for the reports was missed and the reports were not appropriately filed. Recommendation - Management should implement a process to ensure that more than one individual is responsible for monitoring report deadlines and aware of submission requirements for federal awards. Views of Responsible Officials and Planned Corrective Actions - Management agrees with the recommendation and will designate two individuals to monitor federal award reporting deadlines and submission requirements to ensure all required reports are filed. Management has subsequently submitted the 2021 reports to the federal agency.

Assistance Listing Number, Federal Agency, and Program Name - 84.282E, U.S. Department of Education, Charter Schools Program: Grants for Replication and Expansion Federal Award Identification Number and Year - U282E180005, 2018 Pass-through Entity - N/A Finding Type - Material weakness Repeat Finding - No Criteria - In accordance with 2 CFR 200.502(a), the determination of when a federal award is expended must be based on when the activity related to the federal award occurs. Generally, the activity pertains to events that require the nonfederal entity to comply with federal statutes, regulations, and the terms and conditions of federal awards, such as expenditure/expense transactions associated with awards. Condition - The schedule of expenditures of federal awards for the year ended June 30, 2021 includes $392,022 of federal expenditures that were incurred during the prior fiscal year. These expenditures have been appropriately reported to the funding agency. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The schedule of expenditures of federal awards for the year ended June 30, 2021 was overstated by $392,022 due to certain prior year expenditures reported in the current fiscal year. The $392,022 of fiscal year 2020 expenditures were submitted and reimbursed during the year ended June 30, 2021 and included with the total expenditures incurred during the year ended June 30, 2021 on the schedule of expenditures of federal awards. Cause and Effect - The schedule of expenditures of federal awards for the year ended June 30, 2021 included expenditures in the amount of $392,022 related to a prior fiscal year, and, as a result, the current year schedule was overstated by the amount. The $392,022 of fiscal year 2020 expenditures were submitted and reimbursed during the year ended June 30, 2021 and included with the total expenditures incurred during the year ended June 30, 2021 on the schedule of expenditures of federal awards. Recommendation - The Organization should track all federal grant transactions by expenditures, in addition to reimbursement requests, to identify the correct reporting period for expenditures of federal awards. The Organization should implement a formal review process at least annually to reconcile expenditures of grants and review reporting requirements specific to its federal awards. Views of Responsible Officials and Corrective Action Plan - Management agrees with the finding and recommendation provided. Management plans to implement a formal review process on an annual basis for all federal awards to actively monitor and reconcile expenditures with revenue. Additionally, management plans to incorporate a secondary reviewer of the schedule of expenditures of federal awards to ensure completeness and accuracy.

Assistance Listing Number, Federal Agency, and Program Name - 84.282E, U.S. Department of Education, Charter Schools Program: Grants for Replication and Expansion Federal Award Identification Number and Year - U282E180005, 2018 Pass-through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - In accordance with 2 CFR 200.318(a), the Organization must have and use documented procurement procedures consistent with the procurement standards identified in 2 CFR 200.318 through 200.327 for the acquisition of property or services required under a federal award. In accordance with 2 CFR Sections 200.212 and 200.318(h) and 2 CFR Section 180.300, the Organization's procedures must also include procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition - The Organization did not have written procurement procedures to comply with all the regulations included in 2 CFR 200.318 through 200.327. The Organization's internal procurement policies did not include explicit procedures for evaluating proposals, procedures for selecting and rejecting proposals, or the specific methods of procurement to be followed, as required by 2 CFR Section 200.320. Additionally, the Organization did not have controls in place to verify that the vendor selected was not a debarred, suspended, or otherwise excluded entity. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The Organization has written procurement procedures that closely mirror the proposal formal method of procurement, as defined by 2 CFR 200.320, for any purchase of $3,000 or more. However, the policy does not include or reference all of the specifications included in the procurement standards of 2 CFR 200.318 through 200.327. During the grant period, the Organization contracted with a vendor for services totaling $156,717, of which $106,357 was charged to the federal grant, which represents the only contract subject to a formal procurement method for the grant period. The Organization complied with its internal procurement policies to select and approve the vendor. It was concluded that the vendor was not a debarred, suspended, or otherwise excluded entity. Cause and Effect - The Organization does not contract for property or services for amounts greater than $25,000 for any other federal award and was not familiar with the procurement policy and documentation requirements required by 2 CFR 200.318 through 200.327. As a result, the Organization's existing internal procurement requirements did not include all of the requirements of the procurement standards. Recommendation - The Organization should formally implement and document internal procurement standards consistent with 2 CFR 200.318 through 200.326. Additionally, the Organization should identify individuals responsible for reviewing procurement requirements for any federal award received to ensure understanding and appropriate compliance with requirements. Views of Responsible Officials and Planned Corrective Actions - Management agrees with the finding and plans to implement and document internal procurement standards consistent with 2 CFR 200.318 through 200.327. Additionally, the Organization will identify individuals responsible for reviewing procurement requirements for any federal award received to ensure understanding and appropriate compliance of requirements.