Archdiocese of St. LouisNon-Profit

Finding 2024-001 Significant Deficiency: Reporting - Control Finding ALN: 93.558 - 477 Cluster: Temporary Assistance for Needy Families (TANF) Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: Lutheran Family and Children's Services of Missouri Criteria or Specific Requirement: The Uniform Guidance requires that controls over compliance be properly designed, in place, and operating effectively to ensure compliance with the requirements of the federal program. Condition: We noted through procedures performed that management did not perform a complete review of monthly financial reimbursement reports to ensure accuracy prior to the reports being submitted to the pass-through entity. Cause: Internal controls over compliance put in place by management were not designed effectively to ensure a review of financial reimbursement reports was performed and that proof of such reviews was documented and retained. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance relating to reporting. Questioned Costs: Not applicable. Context: 4 out of 4 monthly reimbursement reports tested did not have proof of review documented and retained prior to submission to the pass-through entity. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management assign the review of these reports to an individual who is knowledgeable of the program to ensure that reports are complete and accurate prior to submission, and that such reviews are documented. Views of Responsible Officials: Good Shepherd Children and Family Services (GS) will implement a control procedure to ensure proper review of monthly financial reimbursement reports for accuracy. The Archdiocese Finance Office accountant will prepare monthly reports. Reports and supporting documents will be sent to GS's Chief Program Officer and Pregnancy & Parenting Services Program Director. GS management will review and approve the reports, then submit them via email with approvals for reimbursement.

Finding 2024-002 Significant Deficiency: Procurement and Suspension and Debarment - Control Finding ALN: 21.027 - Coronavirus State and Local Fiscal Recovery Funds Federal Agency: U.S. Department of the Treasury Pass-Through Entity: Missouri Department of Social Services Criteria or Specific Requirement: According to Uniform Guidance, 2 CFR Section 180.300, non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity. Condition: We noted through procedures performed that management did not maintain documentation to support whether or not a suspension or debarment verification was performed prior to entering into covered transactions with entities. In addition, a certification was not obtained from the entities nor was a clause added to the contract. Cause: Internal controls over compliance put in place by management were not designed effectively to ensure evidence of the SAM verification was maintained. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance relating to reporting. Questioned Costs: Not applicable. Context: An exception was noted in the two covered vendor transactions sampled out of the population of four. The vendors tested in the transactions sampled were not suspended or debarred. Statistical sampling was not used to test this compliance requirement. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management amend its procurement policy to require a SAM verification is performed prior to entering into contracts or covered transactions. Views of Responsible Officials: St. Patrick Center will update the agency procurement policy requiring a SAM verification for any vendors that receive contracts or are to be used in covered transactions.

Finding 2023-002 Significant Deficiency: Matching, Earmarking, and Level of Effort – Control Finding ALN 14.267 – Continuum of Care Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entity: City of St. Louis Department of Human Services Criteria or Specific Requirement: The Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: We noted through procedures performed that management did not perform a complete review of match information to ensure its accuracy, prior to it being submitted to the pass-through entity. Cause: Internal controls over compliance put in place by management were not designed effectively to ensure a review of expenditures required to be matched by the Archdiocese was performed and that proof of such reviews was documented and retained. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance relating to reporting. Questioned Costs: Not applicable. Context: Six out of 40 match expenditures sampled, related to in-kind work hours, did not have a proof of review documented and retained prior to submission to the pass-through entity. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management assign the review of these types of expenditures to an individual that is directly supervising the volunteers. In addition, a schedule should be created to document the in-kind hours worked by each volunteer to retain as support for the expenditures. Views of Responsible Officials: St. Patrick Center (SPC) will develop a control procedure to put in place to have In-Kind work hours reviewed by supervisor of volunteers. The supervisor will have volunteers sign-off on their volunteer hours worked. The volunteer sign-off sheets will be reviewed and a report tabulating monthly total hours will be developed. The volunteer supervisor will sign-off on the report, and the volunteer’s supervisor, after their review, prior to forwarding to finance. SPC will retain sign-off reports for reference as needed for audit purposes. Finance will review calculation of match total when processing monthly invoice

Finding 2023-003 Significant Deficiency: Cash Management – Control Finding ALN 17.805 – Homeless Veterans’ Reintegration Program Federal Agency: U.S. Department of Labor Pass-Through Entity: None, direct award to St. Patrick Center Criteria or Specific Requirement: The Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: We noted through procedures performed that management did not perform a review of a reimbursement request to ensure its accuracy, prior to it being submitted to the federal agency. Cause: Internal controls over compliance put in place by management were not designed effectively to ensure a review of reimbursement requests was performed, documented and retained. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance relating to cash management. Questioned Costs: Not applicable. Context: For a sample of two requests, one reimbursement packet request was not reviewed for accuracy prior to its submission to the federal agency. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that reimbursement requests submitted to federal agencies are reviewed by someone knowledgeable about federal grants and be retained in a shared location to prevent the loss of data when there is turnover. Views of Responsible Officials: St. Patrick Center (SPC) will review reimbursements prior to forwarding to the federal grant agency. The Senior Director of Finance or designate, will review the invoices for accuracy. An initial or signature will be added to the reimbursement request, validating review was completed. After review is completed and signature/initial obtained, the reimbursement will be forwarded to the appropriate agency for payment.

Finding 2022-002 Material Weakness: Schedule of Expenditures of Federal Awards ? Control Finding ALN 93.498 ? Provider Relief Fund (PRF) and American Rescue Plan Rural Distribution Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: None, direct awards Criteria or Specific Requirement: 2 CFR section 200.510 states that the auditee must prepare the schedule of expenditures of federal awards (SEFA or ?Schedule?) and the schedule must provide total federal awards expended for each individual ALN and amounts passed through to subrecipients. Condition: During the audit, the following corrections were made to the SEFA: ? PRF amounts totaling $903,155 received during the period of July 1, 2020 through June 30, 2021 were added to the SEFA, in accordance with guidance set forth by the U.S. Department of Health and Human Services. ? Federal expenditures totaling $147,262 were classified under the wrong ALN. The reclassification of these expenditures resulted in a change to the major program determination. ? Federal expenditures were adjusted by $100,152 to accrue reimbursable expenditures related to fiscal year 2022. ? The Schedule provided did not identify amounts passed through to subrecipients. Cause: Management does not have an internal control process in place to ensure an accurate Schedule. Effect: The possibility exists that errors within the Schedule could become material to the financial statements or result in an incorrect major program determination. Questioned Costs: Not applicable. Context: A sufficient review of the Schedule did not occur so errors were not detected. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management assign the review of the SEFA to an individual that is knowledgeable about federal grants. In addition, grant agreements should be retained in a central repository to aid in the review of the SEFA. Lastly, the Finance Office should perform a year-over-year comparison of the SEFA by ALN and make inquiries of agencies regarding significant variances. Views of Responsible Officials: Management will implement procedures to assure that all costs charged to the Provider Relief Fund are reviewed by a competent individual, and those reviews will be documented.

Finding 2022-003 Significant Deficiency: Procurement, Suspension and Debarment ? Compliance and Control Finding ALN 14.231 - Emergency Solutions Grant Program Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entities: City of St. Louis, St. Louis County, Missouri Housing Development Commission Criteria or Specific Requirement: 2 CFR section 200.3018 requires grantees have and use documented procurement procedures in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. The Uniform Guidance also restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with these requirements. Condition: We noted through procedures performed that property and services were purchased under federal grants using a process that did not adhere to the requirements of the Uniform Guidance. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement, suspension and debarment requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: Equipment and services totaling $27,700 and $50,000, respectively, were purchased under the federal grant without obtaining quotes or using a competitive bid process. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views of Responsible Officials: St. Patrick Center (SPC) will review its Procurement Policy to ensure its policy includes all of the procurement, suspension and debarment requirements of the Uniform Guidance. In addition, SPC will investigate and implement a control procedure that will ensure proper internal controls are in place for compliance with these Uniform Guidance requirements. For example, a checklist outlining these requirements could be completed and approved by the appropriate personnel for applicable grants to ensure adequate internal controls are in place for compliance. Also, SPC will hold a training session with all personnel involved in this process to help ensure compliance with these procurement, suspension and debarment requirements of the Uniform Guidance. New hires involved this process will also receive training on these requirements during the new hire training sessions. In addition, SPC will maintain supporting documentation to show compliance with these requirements.

Finding 2022-004 Significant Deficiency: Reporting ? Control Finding ALN 93.498 ? Provider Relief Fund (PRF) and American Rescue Plan Rural Distribution Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: None, direct award to Child Center~Marygrove Criteria or Specific Requirement: The Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: We noted through procedures performed that management did not perform a review of information prior to it being submitted to the U.S. Department of Health and Human Services to ensure its accuracy. Cause: Internal controls over compliance put in place by management were not designed effectively to ensure a review of reports required by the federal grant was performed and that proof of such reviews was documented and retained. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance relating to reporting. Questioned Costs: Not applicable. Context: The PRF report for the period tested was not reviewed for accuracy prior to its submission to the PRF Reporting Portal. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that electronic copies of reports submitted to federal agencies, as well as a documented review of those reports, be retained in a shared location to prevent the loss of data when there is turnover. Views of Responsible Officials: Marygrove CFO will create electronic folders on our system that include subfolders for each report filed. The subfolder will contain all reports and correspondences used to create the required filing. Once the filing is created it will be forwarded to the CEO or the CFOO of Catholic Charities (CFOO) for review prior to submission. Once the CEO or CFOO approves the report, the filing will be finalized in the PRF Reporting Portal. A copy of the final report and copies of all emails related to the review will be retained in the corresponding subfolder.

Finding 2021-003 Significant Deficiency: Allowable Costs & Activities, Period of Performance - Control Finding ALN 21.019 - Coronavirus Relief Fund Federal Agency: U.S. Department of the Treasury Pass-Through Entity: City of St. Louis, Missouri Criteria Or Specific Requirement: Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: A second review to verify that costs charged to the grant were allowable and incurred within the period of performance did not occur. Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: Internal controls as designed by St. Patrick Center to ensure costs charged to the grant were allowable and incurred within the period of performance did not occur. A second review did not occur for 1 of 41 expenditures tested for allowability and proper period of performance. Statistical sampling was not used to test this compliance requirement. Identification as a repeat finding: Not applicable. Recommendation: We recommend that management review its processes and controls surrounding applicable compliance requirements to improve the existing system such that it will ensure compliance with the requirements of federal grants. Views of Responsible Officials: Management will implement procedures to assure that all costs charged to the Coronavirus Relief Fund are reviewed by a competent individual, and those reviews will be documented.

Finding 2021-004 Significant Deficiency: Matching ? Compliance and Control Finding ALN 93.243 - Substance Abuse and Mental Health Services Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: None, direct award to Queen of Peace Center Criteria Or Specific Requirement: 2 CFR section 200.307 provides guidance for matching funds. A non-federal entity?s match or cost share must be verifiable from the entity's records, must not be included as contributions for any other federal award, must be necessary and reasonable for accomplishment of project or program objectives, must be allowable under other sections of the Uniform Guidance, and must not be paid by the federal government under another federal award. In addition, Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: We noted through procedures performed that one employee time allocation in May and June did not agree with internal allocation schedule for match by 1%. Internal controls designed for this federal program did not detect these errors. Internal controls designed for this federal program did not detect these errors. Cause: Controls over compliance put in place by management were not designed effectively to ensure that the match was properly supported by internal records. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Known questioned costs less than $25,000. Context: Two of 37 items selected for testing for match of payroll costs did not conform to the employee?s time allocation schedule that was retained by management. Identification as a repeat finding: This finding is a repeat of some elements of finding 2020-006 from the prior year?s schedule of findings and questioned costs. Recommendation: We recommend that amounts charged as match are reviewed regularly to ensure match amounts are properly supported by internal records. Views of Responsible Officials: Controls were put into place during this fiscal year to review match funding on a monthly basis. The findings identified occurred prior to the controls being implemented, and although one employee was over allocated on match by one percent, our total match amount exceeded the minimum needed for the grant year. Internal reviews of these costs occur monthly and we will further ensure that these measures will also review the match allocation.

Finding 2020-004 Significant Deficiency: Eligibility - Control Finding CFDA 94.011 - Foster Grandparent Program Federal Agency: Corporation for National and Community Service Pass-Through Entity: None, direct award to Cardinal Ritter Senior Services Criteria Or Specific Requirement: The compliance provisions of the federal program require the performance of participant eligibility determinations. Additionally, Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: A second review to verify accuracy of participant file documentation did not take place. Cause: Controls over compliance are not in place as it relates to determining participant eligibility. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance relating to eligibility determinations. Questioned Costs: Not applicable. Context: Cardinal Ritter Senior Services did not have internal controls put in place to ensure the accuracy of participant file documentation and program eligibility. Statistical sampling was not used to test this compliance requirement. Identification as a repeat finding: Not applicable. Recommendation: We recommend that management put a control in place for a second review of participant files once eligibility is determined. The second review should be properly documented with the reviewer?s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant?s eligibility requirements. Views of Responsible Officials: Internal controls will be put in place to review participant eligibility on a quarterly basis at Cardinal Ritter. Monitoring and review of compliance requirements are intended to happen during the eligibility review process to ensure participants selected are eligible. All documents will be retained by Cardinal Ritter.

Finding 2020-005 Significant Deficiency: Matching, Reporting - Control Finding CFDA 93.243 - Substance Abuse and Mental Health Services Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: None, direct award to Queen of Peace Center Criteria Or Specific Requirement: The compliance provisions of the federal program require a non-federal match and certain periodic reporting. Additionally, Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: A second review to verify the accuracy of costs claimed as match was not documented. A second review of annual reports required by the contract was not documented. Cause: Controls over compliance put in place by management were not documented as it relates to these compliance requirements. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not Applicable. Context: Internal controls as designed by Queen of Peace Center to ensure costs claimed as match are met and the propriety of reimbursement requests consist of a documented second review of monthly requests for reimbursement prior to submission. This internal control was not in place during the current year. There were three annual reports required and submitted by Queen of Peace Center and all three lacked documentation of a review by someone other than the preparer. Statistical sampling was not used to test this compliance requirement. Identification as a repeat finding: This finding is a repeat of some elements of finding 2019-006 from the prior year?s schedule of findings and questioned costs. Recommendation: We recommend that management perform its second reviews over match and reporting and ensure the reviews are properly documented with the reviewer?s signature and the date the review was performed. A second review should be performed by someone other than the preparer and who has knowledge of the grant requirements. Views of Responsible Officials: Controls for review were put into place during the year; however, documentation of the review was not available at Queen of Peace Center. Controls were reviewed and reinforced in October 2020 to ensure that all reporting (including match information) that is submitted by Queen of Peace Center is printed, along with email confirmation of submission, signed and dated by the preparer. The secondary reviewer?s approval is documented by signing and dating next to the preparer?s signature, or by sending an email approval message that is printed and retained for the file. The printed reports and corresponding confirmations will be filed at Queen of Peace Center. All monitoring and review of compliance requirements is intended to happen during the reimbursement request (reporting) preparation and review process.

Finding 2020-006 Material Weakness: Allowable Costs & Activities ? Compliance and Control Finding CFDA 93.243 - Substance Abuse and Mental Health Services Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: None, direct award to Queen of Peace Center Criteria Or Specific Requirement: 2 CFR sections 200.420 through 200.475 provide the principles to be applied in establishing the allowability of certain items of cost. Section 200.430 states that budget estimates do not qualify as support for charges to federal awards but may be used for interim accounting purposes as long as all necessary adjustments are made such that the final amounts charged to the federal award are accurate, allowable, and properly allocated. In addition, Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: We noted through procedures performed that some payroll costs charged to the grant were based on estimates or budgeted amounts instead of actual costs incurred. Internal controls designed for this federal program did not detect these errors. Cause: Controls over compliance put in place by management were not designed effectively to ensure allocated costs charged to the grant were based on final amounts supported by internal records. Effect: Instances of noncompliance were not detected by management. Questioned Costs: $31,388 Context: Six of the 31 items selected for tested for allocated payroll costs did not conform to the payroll allocation schedules that were retained by management, which resulted in questioned costs. Additionally, two of 29 items selected for testing for non-payroll related costs were based on estimates instead of actual charges relating to that month. Identification as a repeat finding: Not Applicable Recommendation: We recommend that management change its cost allocation procedures to ensure that final amounts charged to the federal award are accurate, allowable, and properly allocated. Management should adjust its time-keeping process to verify that salaries being charged to the grant are accurate based on the employee?s time spent working specifically on that grant. For non-payroll related items, we recommend that management charge only actual costs to the grant or true up the costs in the following month, if necessary. Internal controls over allowable costs and activities should ensure procedural improvements are implemented properly. Views of Responsible Officials: Internal controls have been put in place to review payroll and other allocated costs on a monthly basis at Queen of Peace Center. Monitoring and review of compliance requirements are intended to happen during the allocation review process to ensure amounts charged are allocated properly. All documents will be retained by Queen of Peace Center.

Finding 2019-004 Significant Deficiency: Special Tests and Provisions - Control Finding CFDA 14.267 - Continuum of Care Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entity: City of St. Louis Department of Human Services Criteria Or Specific Requirement: Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: A second review to verify accuracy of participant file documentation including rent reasonableness documentation, housing quality inspection documentation and income determinations was not properly documented. Cause: Controls over compliance put in place by management were not operating effectively as it relates to special tests and provisions such as rent reasonableness documentation, housing quality inspection documentation and income determinations. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance relating to these special tests and provisions. Questioned Costs: Not Applicable Context: Internal controls as designed by St. Patrick Center to ensure the accuracy of participant file documentation including rent reasonableness documentation, housing quality inspection documentation and income determinations consist of a second review of participant files. RubinBrown sampled ten participant files (20% of population) for the internal control. RubinBrown noted three of ten participant files did not have a properly documented review of the file by someone other than the file preparer. Statistical sampling was not used to test this compliance requirement. Identification as a repeat finding: This finding is a repeat of some elements of finding 2018-010 from the prior year?s schedule of findings and questioned costs. Recommendation: We recommend that management ensure the reviews are properly documented with the reviewer?s signature and the date the review was performed. A second review of grant information should be performed by someone other than the preparer who has knowledge of the grant requirements. Views of Responsible Officials: Management at St. Patrick Center has implemented a process that will ensure all files are initially prepared by an individual who is familiar with all the necessary documents, which are retained in the file as required by the grant terms. A second review is conducted by someone other than the preparer who also has intimate knowledge of grant requirements. This second file review is conducted in a timely manner and will be kept in the client file.

Finding 2019-005 Significant Deficiency: Allowable Costs & Activities, Cash Management, Matching, Level of Effort, and Earmarking - Control Finding CFDA 16.575 - Crime Victim Assistance Federal Agency: U.S. Department of Justice Pass-Through Entity: Missouri Department of Social Services Criteria Or Specific Requirement: Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: A second review to verify allowability of costs and activities charged to the grant, the accuracy of costs claimed as match and that all costs were incurred prior to request for reimbursement was not properly documented. Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not Applicable Context: Internal controls as designed by St. Martha?s Hall to ensure the allowability of costs and activities charged to the grant, the accuracy of costs claimed as match and the propriety of reimbursement requests consist of a second review of monthly requests for reimbursement prior to submission. This internal control was not in place prior to March 2019; as a result, 24 of 40 sampled expenditures and 11 of 18 sampled match costs were not reviewed by someone other than the preparer. Statistical sampling was not used to test this compliance requirement. Identification as a repeat finding: Not Applicable Recommendation: We recommend that management review its processes and controls surrounding applicable compliance requirements to improve the existing system such that it will ensure compliance with the requirements of federal grants. We also recommend that management perform its second reviews more timely and ensure the reviews are properly documented with the reviewer?s signature and the date the review was performed. A second review of grant information should be performed by someone other than the preparer who has knowledge of the grant requirements. Views of Responsible Officials: St. Martha?s Hall has implemented all requirements for secondary reviews of all grant expenditures by agency management. All invoices of expenditures now have two signatures, one from the preparer of the invoice and one from management. Both reviews of the invoice and the approving signatures are dated in a timely manner, meeting the time requirement of the pass-through entity, the Missouri Department of Social Services.

Finding 2019-006 Material Weakness: Allowable Costs & Activities, Cash Management, Matching, Level of Effort, and Earmarking, Period of Performance, Reporting - Control Finding CFDA 93.243 - Substance Abuse and Mental Health Services Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: None Criteria Or Specific Requirement: Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: A second review to verify allowability of costs and activities charged to the grant, the accuracy of costs claimed as match, that costs charged to the grant were in the period of performance, and that all costs were incurred prior to the request for reimbursement was not properly documented. A second review of annual reports required by the contract was not properly documented. Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not Applicable Context: Internal controls as designed by Queen of Peace Center to ensure the allowability of costs and activities charged to the grant, the accuracy of costs claimed as match, period of performance requirements are met and the propriety of reimbursement requests consist of a documented second review of monthly requests for reimbursement prior to submission. This internal control was not in place for most of the fiscal year; and as a result, 49 of 60 expenditures tested for allowability, 35 of 35 sampled match selections and 5 of 5 expenditures tested for proper period lacked documentation of a review by someone other than the preparer. There were two annual reports required and submitted by Queen of Peace Center and both lacked documentation of a review by someone other than the preparer. Statistical sampling was not used to test this compliance requirement. Identification as a repeat finding: Not Applicable Recommendation: We recommend that management review its processes and controls surrounding applicable compliance requirements to improve the existing system such that it will ensure compliance with the requirements of federal grants. We also recommend that management perform its second reviews more timely and ensure the reviews are properly documented with the reviewer?s signature and the date the review was performed. A second review of grant information should be performed by someone other than the preparer who has knowledge of the grant requirements. Views of Responsible Officials: Controls were put into place before the end of the fiscal year to assure that all reporting that is submitted by Queen of Peace Center is printed, along with email confirmation of submission, signed and dated by the preparer. The secondary reviewer?s approval is documented by signing and dating next to the preparer?s signature, or by sending an email approval message that is printed and retained for the file. The printed reports and corresponding confirmations will be filed at Queen of Peace Center.

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION