Volunteers of America Minnesota and WisconsinNon-Profit

Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Special Programs for the Aging – Title III Part C Nutrition Services Assistance Listing Number: 93.045 Pass-Through Agency: Trellis Area Agency on Aging Pass-Through Number(s): 311-23-003C-118-001, 311-24-003C-118-001 Award Period: 2023 and 2024 Type of Finding: * Significant Deficiency in Internal Control over Compliance * Other Matters Criteria or specific requirement: Title 2, Part 200, Subpart D, 200.332(b)(1) requires that subawards must be clearly identified to the subrecipient and include various information, including the Assistance Listing Number (ALN), Federal agency name, and clear identification of the subaward. Condition: For the three subawards viewed, the Assistance Listing Number, Federal agency name, and subaward identification was not included. Context: Other required information, including the subrecipient name, UEI number, budget period, and funding requirements, were noted in the agreement. However, the agreement was not clearly identified as being a subaward (referred to as a contractor), and the Federal agency name and ALN were not included. Cause: The subaward template used did not include the required components. Effect: Subrecipients may not be aware of the requirements of the federal funding. Recommendation: We recommend careful review of the Uniform Guidance requirements for subaward contracts in comparison to subaward agreement templates to identify requirements and updates needed. Views of responsible officials: There is no disagreement with the audit finding.

2022-002 Federal agency: Department of Health and Human Services (DHHS) Federal program title: Provider Relief Fund and American Rescue Plan Rural Distribution Assistance listing number: 93.498 Award period: Period 2, July 1, 2020 ? December 31, 2020 Type of finding: Material Weakness In Internal Control Over Compliance and Other Matters Compliance requirement: Allowable Costs Criteria: Provider Relief Funds (PRF) are to be used to prevent, prepare for, and respond to coronavirus. Provider Relief Funds contained specific terms and conditions requiring recipients to certify that payments would only be used for these certain purposes. DHHS issued guidance and examples on types of allowable expenses. Condition: The Organization claimed expenses in its reporting to DHHS that were not eligible expense under the terms and conditions of PRF. Context: During the audit, it was determined that 3 of 60 expenditures claimed did not meet the criteria developed under the Department of Health and Human Services guidelines for the use of Provider Relief Funds. The total amount of these costs was $164.16. Cause: Management oversight. Effect: The Organization claimed costs that were not eligible for the program. Recommendation: We recommend management develop proper controls over the review of federal expenditures for accuracy and allowability under the criteria provided by the Department of Health and Human Services. However, it was noted that the Organization has enough excess lost revenue to cover the disbursements noted above. View of Responsible Officials: Management will review all expenditures to determine allowability under the specific grant's rules and regulations.

2019-002 Federal agency: Corporation for National and Community Service Federal program title: Retired and Senior Volunteer Program CFDA Number: 94.002 Pass-Through Agency: n/a Pass-Through Numbers: n/a Award Period: April 1, 2016 ? March 31, 2019, April 1, 2019 ? March 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 ?200.303 (a) states that a non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During our testing over cash management and reporting, it was noted that a control process over both compliance requirements had not been established by the entity. Context: Cash requests and financial reports tested did not have a documented review. Cause: Review processes prior to submission had not been implemented by management. Effect: When internal controls are not functioning as designed, errors or noncompliance can occur. Repeat Finding: Not a repeat finding. Recommendation: We recommend the Organization design controls to ensure all cash requests and reports are reviewed prior to submission. View of responsible officials: There is no disagreement with the audit finding.

2019-003 Federal agency: Corporation for National and Community Service Federal program title: Retired and Senior Volunteer Program CFDA Number: 94.002 Pass-Through Agency: n/a Pass-Through Numbers: n/a Award Period: April 1, 2016 ? March 31, 2019, April 1, 2019 ? March 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: 2 CFR Part 200 ?200.309 states that a non-Federal entity may charge to the Federal award only allowable costs incurred during the period of performance. Condition: During our testing of the period of performance, we noted payroll expenses were charged to the grant award starting April 1, 2019, which were incurred prior to that date. Context: Payroll expenses for March of 2019 were charged to the grant, which began on April 1, 2019. Cause: Payroll expenses were charged to the grant based on the date paid instead of the date incurred. Effect: Expenses incurred prior to the start of the grant period were charged to the grant. Repeat Finding: Not a repeat finding. Recommendation: We recommend the Organization design procedures to ensure a proper cutoff of expenses between grant award periods. View of responsible officials and corrective action plan: There is no disagreement with the audit finding.

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