RCS EMPOWERS, INC.Non-Profit

2020-001 Significant Deficiency Identification of the Federal Programs: Federal Agency: Department of Treasury Pass-through Entity: Wisconsin Department of Health Services Development CFDA Number: 21.019 Federal Program Title: Coronavirus Relief Fund Award Period: March 1, 2020 ? August 31, 2020 Federal Agency: Department of Health and Human Services CFDA Number: 93.498 Federal Program Title: Provider Relief Fund Award Period: March 1, 2020 ? December 31, 2020 Criteria: The Code of Federal Regulations (CFR) Section 300.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition: During our testing, we noted that documentation of personnel time, approval for expenses, and lost revenue charged to these grants was compiled after the grant periods ended and were not properly documented during the year. Cause: Due to the need for emergency funds to help the Organization during the pandemic and a lack of timely and sufficient guidance on compliance requirements, management was not aware of specific compliance and reporting requirements for expenses and lost revenue that could be charged to these grants until the grant period was over. Effect: Unallowable costs could be charged to federal awards and not be detected and corrected. Questioned Costs: None Recommendation: We recommend the Organization document time spent on activities and approval of expenses for all government grants when the activities are performed and expenses are incurred, regardless of grant compliance requirements. Views of Responsible Officials and Planned Corrective Actions: Management disagrees with the finding and stated that they followed all compliance per any and all guidance that was available to them throughout the grant period. They did not have any guidance for CARES Act funding from the state other than what was needed to prove they qualified to receive assistance. Management said they practiced very good internal controls and proactively called their contacts at the State and documented what they were told regarding additional guidance.