BALTIMORE CORPS, INCNon-Profit

Finding 2024-002 Corporation for National and Community Service Federal Assistance Listing No. 94.006 AmeriCorps State and National Material Weakness In Internal Controls and Noncompliance over Activities Allowed or Unallowed and Allowable Costs/Cost Principles (Payroll) Repeat Finding: Yes, 2023-002 Condition: For 12 out of 28 payroll selections, we did not receive support to test that payroll charges to the AmeriCorps program were for actual time and effort spent on the grant. Criteria: In accordance with 2 CFR 200.514: (c) Internal controls, (1) The compliance supplement provides guidance on internal controls over federal programs based upon the guidance in Standards for Internal Control in the Federal Government issued by the Comptroller General of the United States and the Internal Control - Integrated Framework, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). COSO requires entities to establish and maintain effective internal controls to achieve operational, reporting and compliance objectives. In accordance with 2 CFR 200.430: (i) Standards for Documentation of Personnel Expenses (1) Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one federal award; a federal award and non-federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: BCI did not have proper controls in place to ensure that payroll activities charged were based on actual work performed on the grant. Effect: BCI is not in compliance with activities allowed and allowable costs (payroll) requirement for the AmeriCorps program. Unallowed payroll costs could be charged to the grant. Questioned Costs: Unknown. Recommendation: We recommend that BCI establish written procedures related to federally funded payroll to ensure the charges are based on time and effort spent working on the grant and implement these procedures immediately. Auditee Response and Corrective Action Plan: Refer to management’s corrective action plan. Auditor’s Conclusion: Finding remains as stated.

Finding 2024-003 Corporation for National and Community Service Federal Assistance Listing No. 94.006 AmeriCorps State and National Significant Deficiency in Internal Controls and Noncompliance over Eligibility Repeat Finding: No Condition: For 3 of 25 members selected for testing, the subsistence allowance to be paid was not specified in the signed agreements. In addition, for 6 of 25 members, the service period outlined in the agreement covered only two months of the audit year, and BCI was unable to provide updated agreements to support the remaining months within fiscal year 2025. Criteria: In accordance with 2 CFR 200.514: (c) Internal controls, (1) The compliance supplement provides guidance on internal controls over federal programs based upon the guidance in Standards for Internal Control in the Federal Government issued by the Comptroller General of the United States and the Internal Control - Integrated Framework, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). COSO requires entities to establish and maintain effective internal controls to achieve operational, reporting and compliance objectives. Per 45 CFR §§ 2540.200–2540.207, recipients of AmeriCorps federal awards must conduct, review, and document National Service Criminal History Checks (NSCHC) for all covered individuals. All components must be completed, adjudicated, and an eligibility determination made no later than the day before an individual begins work or service on an NSCHC-required grant. Individuals registered, or required to be registered, as sex offenders, or who have been convicted of murder, are ineligible to work or serve on an AmeriCorps grant. Additionally, AmeriCorps requires that a signed member agreement, a compensation letter confirming the approved rate, and supporting payroll documentation be maintained for each member. Compensation must not exceed 200% of the members’ total average annual subsistence allowance provided to vista volunteers. Cause: BCI’s internal controls over member file documentation of the signed agreements were not consistently followed and did not ensure that all required AmeriCorps documentation was obtained and retained in the member files. Effect: Failure to maintain required member documentation increases the risk of noncompliance with AmeriCorps program requirements and may result in questioned costs, monitoring findings, or potential disallowance by the granting agency. Questioned Costs: Unknown. Recommendation: We recommend that BCI strengthen its onboarding and document retention procedures to ensure all member files include the required AmeriCorps documentation, including the signed member agreement. Auditee Response and Corrective Action Plan: Refer to management’s corrective action plans. Auditor’s Conclusion: Finding remains as stated.

Finding 2024-004 Programs: All Significant Deficiency in Internal Controls and Noncompliance Over Reporting Repeat Finding: Yes, 2023-004 Condition: BCI’s single audit report and the data collection form were not completed within nine months after the end of the audit period. Criteria: Per 2 CFR 200.512: Report Submission. (a) General. (1) The audit must be completed and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt of the auditor’s report(s), or nine months after the end of the audit period. If the due date falls on a Saturday, Sunday, or federal holiday, the reporting package is due the next business day. (2) Unless restricted by federal statutes or regulations, the auditee must make copies available for public inspection. Auditees and auditors must ensure that their respective parts of the reporting package do not include protected personally identifiable information. Cause: BCI’s fiscal year 2024 single audit was not completed within the nine months after the end of the audit period. BCI did not have the policies and resources in place to complete a single audit in a timely manner. Effect: Failure to submit the reporting package and data collection form within the required timeframe results in non-compliance with the Uniform Guidance reporting requirements. Questioned Costs: None. Recommendation: We recommend that BCI creates policies and procedures to ensure that audits are started and completed in a timely fashion so the reporting package submission to the federal government can be made in accordance with federal guidelines. We also recommend that individuals responsible for administering federal assistance programs with BCI receive training in grant administration. Auditee Response and Corrective Action Plan: Refer to management’s corrective action plans. Auditor’s Conclusion: Finding remains as stated.

United States Department of Treasury Federal Assistance Listing No. 21.027 American Rescue Plan Act (ARPA) Federal Assistance Listing No. 94.006 AmeriCorps State and National Material weakness over Activities Allowed or Unallowed and Allowable Costs/Cost Principle (Payroll) Repeat Finding: No Condition: For 25 out of 25 payroll selections, we did not receive support to test that payroll charges to the AmeriCorps and ARPA programs were for actual time and effort spent on the grant. Criteria: In accordance with 2 CFR 200.514: (c) Internal control. (1) The compliance supplement provides guidance on internal controls over Federal programs based upon the guidance in Standards for Internal Control in the Federal Government issued by the Comptroller General of the United States and the Internal Control - Integrated Framework, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). COSO requires entities to establish and maintain effective internal controls to achieve operational, reporting and compliance objectives. In accordance with 2 CFR 200.430: (i) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; and (vi) Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Cause: BCI did not have proper controls in place to ensure that payroll activities charged were based on actual work performed on the grant. Effect: BCI is not in compliance with activities allowed and allowable costs (payroll) requirement for the ARPA program. Unallowed payroll costs could be charged to the grant. Questioned Costs: Unknown. Recommendation: We recommend that BCI establish written procedures related to federally funded payroll (partial and full) to ensure the charges are based on time and effort spent working on the grant and implement these procedures immediately. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the Corrective Action Plan. Auditor’s Conclusion: Finding remains as stated.

United States Department of Treasury Federal Assistance Listing No. 21.027 American Rescue Plan Act (ARPA) Significant deficiency over Procurement and Suspension and Debarment Repeat Finding: No Condition: During our audit we noted that procurement documentation was not available to support the selection of a sole source vendor. Also, we were unable to obtain documentation to support BCI entering into contractual agreements with vendors who were not debarred or suspended from doing business with the Federal government. Criteria: In accordance with 2 CFR 200.514: (c) Internal control. (1) The compliance supplement provides guidance on internal controls over Federal programs based upon the guidance in Standards for Internal Control in the Federal Government issued by the Comptroller General of the United States and the Internal Control - Integrated Framework, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). COSO requires entities to establish and maintain effective internal controls to achieve operational, reporting and compliance objectives. Per 2 CFR 200.320 General procurement stands: (a) Noncompetitive procurement. There are specific circumstances in which noncompetitive procurement can be used. Noncompetitive procurement can only be awarded if one or more of the following circumstances apply: (1) The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold .(2) The item is available only from a single source; (3) The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; (4) The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or (5) After solicitation of a number of sources, competition is determined inadequate. Per 2 CFR 200.318 General procurement stands: (b) The Non-Federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in this part. Per Uniform Guidance, Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. Cause: BCI did not apply the required procurement policy relative to sole source contracts in accordance with Uniform Guidance. Management also did not complete a review of vendors/contractors to verify they are not suspended, debarred, or otherwise excluded before contracting. Effect: The Organization does not have adequate documentation on whether they have entered into transactions with eligible entities and is in compliance with Federal guidelines. Questioned Costs: Unknown Recommendation: We recommend the Organization update and follow their controls to identify vendors that should go through the procurement process. We also recommend the Organization follow their process to verify that entities are not suspended, debarred, or otherwise excluded annually at time of award and to document these procedures. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the Corrective Action Plan. Auditor’s Conclusion: Finding remains as stated.

Significant Deficiency and Noncompliance Over Reporting Repeat Finding: No Condition: BCI’s single audit report and the data collection form were not completed within nine months after the end of the audit period. Criteria: Per 2 CFR 200.512: Report Submission. (a) General. (1) The audit must be completed and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt of the auditor’s report(s), or nine months after the end of the audit period. If the due date falls on a Saturday, Sunday, or Federal holiday, the reporting package is due the next business day. (2) Unless restricted by Federal statutes or regulations, the auditee must make copies available for public inspection. Auditees and auditors must ensure that their respective parts of the reporting package do not include protected personally identifiable information. Cause: BCI’s fiscal year 2023, financial statements and Single Audit was not completed within the nine months after the end of the audit period. BCI did not have the policies and resources in place to complete a single audit in a timely manner. Effect: Failure to submit the reporting package and data collection form within the required timeframe results in non-compliance with the Uniform Guidance reporting requirements. Questioned Costs: None. Recommendation: We recommend that BCI creates policies and procedures to ensure that audits are started and completed in a timely fashion so the reporting package submission to the Federal government can be made in accordance with Federal guidelines. We also recommend that individuals responsible for administering Federal assistance programs with BCI receive training in grant administration. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the Corrective Action Plan. Auditor’s Conclusion: Finding remains as stated.