City of NorfolkLocal Government

Criteria or specific requirement: Control: Per 2 CFR section 200.303(a), 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. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Schools was unable to provide evidence of timesheet approval for 2 of 40 payroll samples tested. Context: Forty timesheets were selected for testing and the following exceptions were noted: • For 2 of 40 timesheets selected for testing, Schools was unable to provide documentation evidencing the timesheets were properly approved. Questioned costs: Not applicable. Cause: Schools’ procedures and controls were not sufficient to ensure that time and effort reporting was accurately performed and documented, nor that employee time was properly allocated and approved. Effect: There is an increased risk of charging unallowed payroll costs to the program. Recommendation: Schools should reevaluate its current process, implement proper controls, and perform additional training over time and effort reporting. Schools should not seek federal reimbursement unless it can substantiate that the time and effort was dedicated to the federal program. Documentation should be readily available for audit.

Criteria or specific requirement: SFAs and sponsors must submit monthly claims for reimbursement for meals and snacks served to eligible students within 60 days following the last day of the month covered by the claim. Each month's claim for reimbursement and all data used in the claims review process must be maintained on file. Accurate records must be maintained justifying all meals claimed and documenting that all Program funds were spent only on allowable Child Nutrition Program costs. Condition: Schools was unable to provide evidence of review and approval for 3 of 3 reporting samples tested. Context: The schools did not properly review and approve 3 of 3 Meal Reimbursement Reports. Questioned costs: Undetermined. Cause: The schools did not have internal controls established to ensure proper review and approval of the NSLP/FFVP Claim Reimbursement Summary/Meal Reimbursement Summary. Effect: There is a risk that meals were submitted for reimbursement; however, they did not qualify. Recommendation: We recommend that the Schools review their policies and procedures to ensure they include proper review and approval of the Meal Reimbursement Reports. Views of responsible officials: The School agrees with this finding. See separate Corrective Action Plan related to this finding.

Criteria or specific requirement: Compliance: 2 CFR §200.332(a) - Requirements for Pass-Through Entities states, in part, that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Control: Per 2 CFR Section 200.303(a), 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. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The City did not furnish all required information to subrecipients at the time the subawards were issued. Context: The City failed to obtain the required Unique Entity Identifier (UEI) from one out of five subrecipients tested and the Federal Award Identification Number (FAIN) from five out of five subrecipients tested in accordance with proper subrecipient monitoring procedures. Questioned costs: None. Cause: The City did not establish effective internal controls and procedures over subrecipient monitoring.Effect: Excluding required federal grant award information at the time of the subaward may cause subrecipients and their auditors to be uninformed about program-specific regulations that apply to the funds they receive. There is also the potential for subrecipients to have incomplete Schedules of Expenditures of Federal Awards (SEFA) in subrecipients’ Single Audit reports, and federal funds may not be properly audited at the subrecipient level in accordance with the Uniform Guidance.Recommendation: The City should review and enhance its internal controls and procedures to ensure that all required information is included in subawards at the time of issuance and maintained in subsequent modifications. Views of responsible officials: The City agrees with this finding. See separate Corrective Action Plan related to this finding.

Criteria or specific requirement: Per 2 CFR section 200.326, nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations. Condition: The contracts and subcontracts did not include the required prevailing wage rate provisions. Context: For all 11 contracts tested, prevailing wage rate clauses were missing in both the contracts or subcontracts. However, the City did obtain certified weekly payrolls from all contractors tested. Questioned costs: Undetermined. Cause: The City failed to adhere to established internal controls over wage rate requirements and related regulations. Effect: Excluding the required prevailing wage rate information in contracts and subcontracts may cause vendors to be uninformed about specific program regulations that apply to the funds they receive. Recommendation: The City should review and enhance its policies and procedures to ensure that all required wage rate provisions are consistently included in contracts and subcontracts. Views of responsible officials: The City agrees with this finding. See separate Corrective Action Plan related to this finding.

Criteria or specific requirement: Per the Virginia Department of Education, the proportionate share set aside amount for each required school divisions must be expended during the grant period on the provision of special education and related services for the parentally-placed private school students with disabilities enrolled in private schools and homeschooled children located in the LEA. Funds not obligated or spent at the end of the first fiscal year of the grant must be carried forward for one additional year. Any unspent funds after the one year carry over period can be spent for the other special education and related services activities. The actual Proportionate Set Aside (PSA) amount for the grant is established based on data submitted during the PSA data collection in the fall and not preliminary amounts included in the annual plan. Condition/Context: The PSA calculation incorrectly reported the number of eligible children with disabilities in the Schools. This error occurred due to inadequate review before the Schools verified the calculation. The error resulted in a higher amount to be expended during the grant period on the provision of special education services than required; therefore, the Schools were still in compliance with the earmarking requirement, as they expended the higher amount. Questioned costs: None. Cause: The Schools lacked established internal controls to ensure a proper review and approval process for the PSA calculation. Effect: Without proper internal controls, the Schools could approve an incorrect PSA calculation and potentially fail to meet the earmarking requirements set for the by the Virginia Department of Education. Recommendation: We recommend that the Schools review and strengthen their policies and procedures to ensure the proper review and approval of the PSA calculation before finalization. Views of responsible officials: The Schools agree with this finding. See separate Corrective Action Plan related to this finding.

Criteria or specific requirement: 22 CFR sections 637.201, 637.205, 637.207 and 637.209: A Local Public Agency (LPA) must have a quality assurance program, approved by the Federal Highway Administration (FHWA), for construction projects on the National Highway System (NHS) to ensure that materials and workmanship conform to approved plans and specifications. Verification sampling must be performed by qualified personnel employed by the State Department of Transportation or its designated agent. Condition/Context: For one out of six construction projects tested, the City could not provide documentation that proper tests were performed in accordance with the quality assurance program and that verification sampling activities were performed by qualified testing personnel. Questioned costs: None. Cause: The City’s procedures and controls were insufficient to ensure that support for testing under the quality assurance program was maintained and readily available for audit. Effect: Without proper testing in accordance with the quality assurance program, there is a risk materials and workmanship for construction projects on the NHS may not conform to approved plans and specifications.Recommendation: We recommend that the City enhance its policies and procedures to ensure proper tests are conducted in accordance with the quality assurance program for construction projects on the NHS and is readily available for audit. Views of responsible officials: The City agrees with this finding. See separate Corrective Action Plan related to this finding

Reference Number: 2021-001 Prior Year Finding: N/A Federal Agency: U.S. Department of Health and Human Services State Agency: N/A Federal Program: HIV Emergency Relief Project Grants ? Ryan White HIV/AIDS Program Part A Assistance Listing Number: 93.914 Award Number and Year: 2 H89HA00053-22-00 ? 03/01/2020 ? 02/28/2021 Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control over Compliance, Material Noncompliance Criteria or specific requirement: Compliance: The HHS Uniform Administrative Requirements, Cost Principles, and Audit Requirements for HHS Awards (45 CFR Part 75) requires pass-through entities: (1) to evaluate each subrecipient?s risk of noncompliance in order to determine the appropriate monitoring level; (2) to monitor the activities of subrecipient organizations to ensure that the subaward is in compliance with applicable federal statutes and regulations and terms of the subaward; and (3) to verify that subrecipients are audited as required under this guidance. Specifically, the grantee must conduct monitoring activities in accordance with sections 75.351 through 75.353 of Subpart D of 45 CFR Part 75. Control: Per 2 CFR section 200.303(a), 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. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our testing of 3 out of 5 subrecipients, the required annual monitoring was not performed. Additionally, for one out of 25 subrecipient reimbursements payments selected for testing, supporting documentation could not be provided, as such we were unable to determine if the costs were in compliance with the program requirements. Context: Per the City of Norfolk Ryan White Part A Program Grants Management Policies and Procedures, ?each Ryan White Part A subrecipient is required to participate in an annual, comprehensive, single-day site visit. Site visits are conducts to determine subrecipient compliance with contractual obligations, program policies, Service Standards, and Ryan White HIV/AIDS Program Federal legislation. Subrecipients will receive a summary of the site visit in the form of a site visit report within 45 days of the completion of the site visit. This summary will include fiscal and programmatic findings and recommendations that are identified based on areas in which the program is out of compliance with legislative and programmatic requirements. It may also include suggestions for improvement, which may not necessarily be a compliance issue. Agencies may be required to submit a Corrective Action Plan (CAP) that addresses the findings of non-compliance. Recipient staff will provide technical assistance to programs to support compliance.? Cause: Per discussion with management, due to lack of resources, the Department did not adhere to its existing internal controls and procedures over subrecipient monitoring. Additionally, we noted management indicated that the related supporting documentation for the subrecipient reimbursement expense was no longer maintained within the City?s record. Effect: Failure to ensure that the required subrecipient monitoring is performed increases the risk that subrecipients may inappropriately spend and/or inaccurately track and report federal funds and any discrepancies may not be detected or corrected on a timely basis. Questioned costs: Undetermined Recommendation: We recommend the Department adhere to its existing internal controls and procedures to ensure that all required subrecipient monitoring is performed and that proper documentation be maintained and available for review in accordance with the respective federal/state maintenance of documentation standards. Views of responsible officials: The City office responsible for the administration of the Ryan White HIV/AIDS Program will enhance existing policies and procedures as well as oversight to ensure compliance requirements are appropriately met. The team will work to review and understand all grant conditions clearly and will devise a mechanism for tracking progress of compliance with these conditions. Document retention policies and procedures will be evaluated and enhanced where necessary. Staffing levels and skillsets will be assessed to ensure they are appropriate. Additionally, cross-training will be provided to program staff to ensure critical tasks have redundancies. The City recognizes the importance of and is committed to ongoing quality improvement and working to improve internal controls that ensure compliance.

2020-001: Federal agency: Department of Health and Human Services Federal program title: Temporary Assistance for Needy Families (TANF) CFDA Number: 93.558 Pass-Through Agency: Virginia Department of Social Services Pass-Through Number(s): None Recipient: City of Norfolk Award Period: July 1, 2019 - June 30, 2020 Type of Finding: Significant Deficiency in Internal Control over Compliance, Noncompliance Criteria or specific requirement: The non-Federal entity must: (a) Establish and maintain effective internal controls 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. These internal controls should be in compliance with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our eligibility testing of the Temporary Assistance for Needy Families (TANF) program, for one out of 40 participants, the Department of Human Services was unable to provide the required birth certificate and the school attendance verification form. Context: There was one instance in which required documents were not maintained that would demonstrate whether the participant was eligible for TANF benefits. Questioned Costs: Indeterminable; As the City is the administrator of these local funds and the Commonwealth of Virginia provides payments directly to the program participants, we were unable to determine if there were questioned costs in relation to this finding. Cause: The case record documentation did not properly maintain two of the required elements due to an oversight and the issue was not identified in the review process. Effect: We were unable to determine if the respective participant was properly determined eligible to receive program benefits. Recommendation: We recommend that the Department of Human Services adhere to its current policies and procedures to ensure that documentation supporting program requirements is maintained and readily available for review.

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION