South Dakota Network Against Family Violence and Sexual Assault

Department of Health and Human Services Federal Financial Assistance Listing 93.591, 2201SDSDVC, 2301SDSDVC, 2101SDSDC6, 2201SDSTC6 Family Violence Prevention and Services/State Domestic Violence Coalitions Procurement, Suspension, & Debarment Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must create 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 the terms and conditions of the federal award. Additionally, 2 CFR 200.320 notes for any of the procurement methods described in the section, the recipient or subrecipient must maintain and use documented procurement procedures, consistent with the standards of the section. Condition: There were two instances where the review and approval process did not identify the correct procurement method on the procurement worksheet. The correct method was used, however was not properly documented on the Organization's internal worksheet. In addition, the contracts tested did not include some of the required provisions. Cause: The Organization’s review process did not identify the errors. Effect: Without following the established procurement procedures, it is difficult to demonstrate compliance with the federal requirements. Questioned Costs: None reported Context/Sampling: There were two contracts entered into during the current year and both were tested. Repeat Finding from Prior Year(s): No Recommendation: We recommend that management review the procurement procedures with applicable employees to ensure procedures are followed going forward. In addition, we suggest management review the contract process to ensure that contracts contain all required contract provisions. Views of Responsible Officials: Management is in agreement.

Finding 2021-002 Department of Justice CFDA 16.021, 2018-FJ-AX-0012, Justice Systems Response to Families CFDA 16.524, 2016-WL-AX-0011, Legal Assistance for Victims Reporting Material Weakness in Internal Control Over Compliance and Noncompliance 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 the terms and conditions of the federal award. 2 CFR Part 170 establishes requirements for recipients? reporting of information on subawards as required by the Federal Funding Accountability and Transparency Act of 2006 (FFATA). Condition: The Network did not complete the required reporting of first-tier subawards under the Federal Funding Accountability and Transparency Act Subaward Reporting System within the required 30 day period after a signed subrecipient agreement is effective. Cause: Management did not believe the reporting was required. Effect: Ineffective controls over this area of compliance could result in a reasonable possibility the Network would be noncompliant with the compliance requirements outlined in the Notice of Award as it relates to FFATA reporting. Questioned Costs: None reported Context: There were four subawards (two for CFDA 16.021 and two for CFDA 16.524) that would have been subject to reporting during the fiscal year. Repeat Finding from Prior Years: No Recommendation: We recommend that management review reporting requirements related to FFATA reporting and develop procedures and control processes as it relates to FFATA reporting. We also suggest that management complete required FFATA reporting. Views of Responsible Officials: Management is not in agreement. See corrective action plan.

Finding 2020-003 Department of Justice CFDA 16.589, 2016-WR-AX-0016 Rural Domestic Violence, Dating Violence, Sexual Assault, and Stalking Assistance Program Reporting Significant Deficiency in Internal Control Over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal controls over the federal awards that provide assurance that the entity is managing the federal awards in compliance with federal statutes, regulations, and the conditions of the federal award. 2 CFR 200.327 and 2 CFR 200.328 require the auditee to collect financial information and monitor its activities under federal awards to assure compliance with applicable federal requirements, to assure performance expectations are being achieved, and to report these items in accordance with program requirements. Condition: Through testing of a progress report submitted, we noted that one of the percentages reported was calculated using the incorrect base, and as a result, was overstated in the report. Through testing of two status reports, we noted that there were differences between the amounts supported and the amounts reported, as management did not retain the documentation used to prepare the reports. Adjustments were posted between the time of preparation of the report and the performance of the testing. Cause: The Network established controls over the review and approval of reports; however, the controls in place did not detect or correct the error in the progress report. The Network did not retain the documentation supporting the amounts reported in the financial status report. Effect: Without retention of the supporting documentation, demonstrating that the program complies with laws, regulations, and other compliance requirements is difficult. Questioned Costs: None reported. Context: A non-statistical sample of 3 reports out of 6 reports was selected for testing. Repeat Finding from Prior Year(s): No Recommendation: We recommend that management review procedures surrounding the preparation of reports and implement procedures requiring the retention of documentation used to prepare the reports. This will provide proper support for the amounts reported and will allow for a more thorough review of calculations to ensure that the underlying numbers reported are accurate. Views of Responsible Officials: Management is in agreement.

Finding 2020-004 Department of Health and Human Services and State of South Dakota CFDA 93.671, FVPS 20-150 Family Violence Prevention and Services/Domestic Violence Shelter and Supportive Services Matching Significant Deficiency in Internal Control Over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal controls over the federal awards that provide assurance that the entity is managing the federal awards in compliance with federal statutes, regulations, and the conditions of the federal award. 2 CFR 200.306 establishes that matching funds must meet certain criteria including being necessary and reasonable for accomplishment of the program objectives and being allowable under Subpart E of 2 CFR 200. Condition: Through testing of costs used to meet the matching requirement, we identified three instances where payroll taxes and benefit rates were applied to volunteer hours and claimed as match in addition to the underlying volunteer hours. These costs were determined to be ineligible as the resulting overall rate exceeded the rate determined allowable by the pass-through agency for uncompensated volunteer hours. Cause: The Network established controls over the review and approval of costs used to meet the matching requirement, but management was unaware that benefits and taxes on volunteer hours claimed for match were ineligible. Effect: Costs were used to meet the matching requirement that were ineligible. However, the Network had enough other eligible costs and therefore the matching requirement was still met. Questioned Costs: None reported. Context: A non-statistical sample of 16 transactions out of 79 total match transactions was selected for testing. Repeat Finding from Prior Year(s): No Recommendation: We recommend that management review procedures surrounding the claiming of volunteer hours used to meet the matching requirement to ensure that costs are eligible. Views of Responsible Officials: Management is in agreement.

Finding 2019-003 Department of Justice CFDA 16.524, 2016-WL-AX-0011 Legal Assistance for Victims Allowable Costs and Activities Significant Deficiency in Internal Control Over Compliance Criteria: The Network is required to have procedures in place to ensure that federal awards are expended only for allowable costs in accordance with Subpart E ? Cost Principles of the Uniform Guidance. Allowable costs should be supported by documentation and charged to the correct account, amount, and period. 2 CFR 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 the terms and conditions of the federal award. Condition: As a result of non-payroll disbursement testing, there was one instance noted where an invoice was not retained to support an expenditure charged to the program. The invoice was able to be subsequently obtained by the Network, but there was no documentation retained to show review or approval of the expenditure before it was paid and submitted for reimbursement under the program. Cause: The Network established controls over the review and approval of non-payroll expenditures; however, the controls in place did not detect nor correct the missing supporting documentation. Effect: Without retention of supporting documentation, demonstrating that the program complies with laws, regulations, and other compliance requirements is difficult. Questioned Costs: None reported. Context Sampling: A non-statistical sample of 29 non-payroll expenditures out of 142 total non-payroll expenditures was selected for testing, which accounted for $76,650 out of total non-payroll expenditures of $182,849. Repeat Finding from Prior Year(s): No Recommendation: We recommend the Network review and strengthen controls surrounding the review and approval of allowable costs and documentation retention. Views of Responsible Officials: Management is in agreement.

Finding 2019-004 Department of Justice CFDA 16.524, 2016-WL-AX-0011 Legal Assistance for Victims Department of Justice CFDA 16.589, 2016-WR-AX-0016 Rural Domestic Violence, Dating Violence, Sexual Assault, and Stalking Assistance Program Department of Justice and State of South Dakota CFDA 16.590, 2016-WE-AX-0003 Grants to Encourage Arrest Policies and Enforcement of Protection Orders Program Procurement, Suspension, and Debarment and Subrecipient Monitoring Significant Deficiency in Internal Control Over Compliance 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. As outlined in 2 CFR 180, recipients must not utilize any vendor or pass through funds to subrecipients which are suspended or debarred or otherwise excluded from the central contractor registry. 2 CFR 200.331(d) establishes that the auditee must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes in compliance with federal statutes, regulations, and terms and conditions of the subaward. Condition: The Network implemented a formal policy relating to compliance with the suspension and debarment compliance requirement of uniform guidance as noted above. However, there was no formal documentation retained to support monitoring controls in place to ensure compliance with the internal policy and compliance requirement, which led to one subrecipient under CFDA 16.524 not being verified against the central contractor registry. Additionally, documentation was not retained to support oversight controls over the subrecipient monitoring process. Cause: The Network retained documentation to support verification of vendors against the central contractor registry; however, there was no formal documentation retained to support oversight over the process. The Network established processes to monitor subrecipients; however, the Network did not establish formal oversight controls over the subrecipient monitoring process. There was no documentation available to support formal controls over subrecipient monitoring. Effect: One subrecipient was not verified against the central contractor registry during the year. Without establishing formal controls and retaining documentation to support the controls in place being performed, demonstrating that the program complies with laws, regulations, and other compliance requirements is difficult. Questioned Costs: None reported. Context Sampling: For CFDA 16.524, sampling was not used. For CFDA 16.589, a non-statistical sample of four subrecipients out of twelve subrecipients was selected for testing. For CFDA 16.590, a non-statistical sample of three subrecipients out of six subrecipients was selected for testing. Repeat Finding from Prior Year(s): Subrecipient Monitoring, Yes; Procurement, Suspension, and Debarment, No Recommendation: We recommend the Network review and strengthen controls surrounding oversight and document retention related to suspension and debarment and subrecipient monitoring. Views of Responsible Officials: Management is in agreement.

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