EIN: 660457131
UEI: HFX9UH52Z8H1
Audited by: GONZALEZ TORRES & CO., CPA, PSC
Oversight agency: 93 [Department of Health and Human Services]
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Data as of August 28, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on June 25, 2025. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by December 25, 2025 (246 days ago).
What is a management decision? →OAE requires the monitoring process of 100% of the population of the subrecipients of federal funds, at least once a year. During the year ended September 30, 2024, the OAE distributed federal funds to 118 subrecipients. However, the subrecipients subjected to formal monitoring were only thirty-eight (38) or 32%. Cause of Condition: For the year ended September 30, 2024, the OAE had inefficient policies and procedures manuals that prevented the full monitoring of all centers. In order to improve efficiency, the OAE implemented a new risk assessment in April 2024 that will allow the centers to be monitored in a shorter time. Effect of Condition: The failure to monitor subrecipients may lead to inappropriate use of funds by the subrecipients, and the disallowance of such costs by the federal agencies. Questioned Costs: None. Prior year finding: 2023-002 Recommendation: OAE should review the design of the internal policies according to the available resources and modify what is established in the State Plan regarding the monitoring of subrecipients. The monitoring processes should be designed to ensure that the grants were used properly, and all supporting documents were properly assembled and stored. Best practices on subrecipients monitoring should be searched and evaluated for implementation. View of Responsible Official and Planned Corrective Action Plan: OAE agrees with the finding and will adhere to the corrective action plan on page 37 in this audit report.
Show full finding ▾Hide full finding ▴Section III. Federal Awards Findings and Questioned Costs Finding 2024-001: Subrecipient Monitoring Type of Finding: Material Weakness (MW), Instance of Noncompliance (NC) Assistance Listing No.: 93.044, 93.045, 93.053, 93.052 Program Title: Title III - B Supportive Services and Senior Centers, Title III - C Nutrition Services, Nutrition Services Incentive Program, and Title III - E National Family Caregiver Support Federal Award Year: 10/1/2023 - 9/30/2024 Federal Award No.: 2401PROASS, 2401PROACM, 2401PROAHD, 2401PROAPH, 2401PROANS Name of Federal Agency: U.S. Department of Health and Human Services (HHS) Name of Pass-through Entity: N/A Criteria: 45 CFR Sections 1321.11(b) and 1321.17(f)(9), the State Agency is required to develop policies governing all aspects of programs operated under the State Plan and to monitor their implementation, including assessing performance for quality and effectiveness and specifying data system requirements to collect necessary and appropriate data. The policies developed by the State agency shall address the way the State agency will monitor the performance of all programs and activities initiated under this part for quality and effectiveness. Statement of Condition: OAE requires the monitoring process of 100% of the population of the subrecipients of federal funds, at least once a year. During the year ended September 30, 2024, the OAE distributed federal funds to 118 subrecipients. However, the subrecipients subjected to formal monitoring were only thirty-eight (38) or 32%. Cause of Condition: For the year ended September 30, 2024, the OAE had inefficient policies and procedures manuals that prevented the full monitoring of all centers. In order to improve efficiency, the OAE implemented a new risk assessment in April 2024 that will allow the centers to be monitored in a shorter time. Effect of Condition: The failure to monitor subrecipients may lead to inappropriate use of funds by the subrecipients, and the disallowance of such costs by the federal agencies. Questioned Costs: None. Prior year finding: 2023-002 Recommendation: OAE should review the design of the internal policies according to the available resources and modify what is established in the State Plan regarding the monitoring of subrecipients. The monitoring processes should be designed to ensure that the grants were used properly, and all supporting documents were properly assembled and stored. Best practices on subrecipients monitoring should be searched and evaluated for implementation. View of Responsible Official and Planned Corrective Action Plan: OAE agrees with the finding and will adhere to the corrective action plan on page 37 in this audit report.
Condition: The Office of the Advocate for the Elderly requires the monitoring process of 100% of the population of the subrecipients of federal funds, at least once a year. During the year ended September 30, 2024, the OAE distributed federal funds to 118 subrecipients. However, the subrecipients subjected to formal monitoring were only fifty one (51) or 43%. Corrective Action Plan: The Office has changed its procedures for conducting monitoring visits. These are now based on a risk-based monitoring approach. This was implemented during 2024, and we have observed an increase in the number of monitoring visits conducted, compared to the finding from 2023, when only 11% of sub-recipients were monitored. During the audited period, this figure increased to 43% of sub-recipients who received monitoring. We expect that for the 2025 Self-Assessment, this issue will no longer be a finding, thereby meeting the required standards. Lead Person for Action Item Completion: Miguel Padilla Vázquez Budget Director Marie M Marrero Garcia Administration Director
2023-002
FAC accepted this audit on March 13, 2025 — management decision was due September 13, 2025.
OAE did not submit the single audit report and reporting package for the year ended September 30, 2023, to the Federal Audit Clearinghouse during the required submission deadline period. Cause of Condition: OAE's Single Audit Report for fiscal year 2022 was submitted on December 3, 2024 by the predecessor auditor. The main causes of the late submissions of the Single Audit Reports of fiscal year 2022 and fiscal year 2023 were the delays experienced in the contract process to engage the external auditors. Effect of Condition: OAE may be subject to sanction, as described in the Uniform Guidance, Section 225 titled "Sanctions", in cases of continued inability to have an audit conducted in accordance with this part. Federal agencies and pass-through entities shall take appropriate actions using sanctions such as: (a) withholding a percentage of federal award until the audit is completed satisfactorily; (b) withholding or disallowing overhead cost; (c) suspending federal award until the audit is conducted, or (d) terminating the federal award. Questioned Costs: None. Prior year finding: 2022-001 Recommendation: We recommend management to formalize a plan to monitor the single audit process, including the engagement of the external auditors, the completion of all required steps, including the access to the required documentation, as well as an itinerary of every relevant step to perform, complete and submit single audit during the required period. View of Responsible Official and Planned Corrective Action Plan: OAE agrees with the finding and will adhere to the corrective action plan on page 41 in this audit report. Responsible Person: Miguel A. Padilla Vázquez-Director of Administration
Show full finding ▾Hide full finding ▴Section III. Federal Awards Findings and Questioned Costs Finding 2023-001: Late submission of single audit report package Type of Finding: Material Weakness (MW), Instance of Noncompliance (NC) Assistance Listing No.: All federal financial assistance listing numbers Program title: All federal financial assistance programs Federal Award Year: 10/1/2022 - 9/30/2023 Federal Award No.: All federal awards Name of federal agency: All federal agencies Name of pass-through entity: All pass-through entities Criteria: 2 CFR Part 200, Subpart C, Section 200.512 established that the audit shall be completed and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section shall be submitted within the earlier of 30 days after receipt of the auditors' report(s), or nine months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Unless restricted by law or regulation, the auditee shall make copies available for public inspection. Statement of Condition: OAE did not submit the single audit report and reporting package for the year ended September 30, 2023, to the Federal Audit Clearinghouse during the required submission deadline period. Cause of Condition: OAE's Single Audit Report for fiscal year 2022 was submitted on December 3, 2024 by the predecessor auditor. The main causes of the late submissions of the Single Audit Reports of fiscal year 2022 and fiscal year 2023 were the delays experienced in the contract process to engage the external auditors. Effect of Condition: OAE may be subject to sanction, as described in the Uniform Guidance, Section 225 titled "Sanctions", in cases of continued inability to have an audit conducted in accordance with this part. Federal agencies and pass-through entities shall take appropriate actions using sanctions such as: (a) withholding a percentage of federal award until the audit is completed satisfactorily; (b) withholding or disallowing overhead cost; (c) suspending federal award until the audit is conducted, or (d) terminating the federal award. Questioned Costs: None. Prior year finding: 2022-001 Recommendation: We recommend management to formalize a plan to monitor the single audit process, including the engagement of the external auditors, the completion of all required steps, including the access to the required documentation, as well as an itinerary of every relevant step to perform, complete and submit single audit during the required period. View of Responsible Official and Planned Corrective Action Plan: OAE agrees with the finding and will adhere to the corrective action plan on page 41 in this audit report. Responsible Person: Miguel A. Padilla Vázquez-Director of Administration
As we mentioned in the SA 2022 Corrective Action Plan, we have been working with Unified Contracts which is helping us achieve our goal. We will continue with a Unified Contract to ensure that SA 2024 can be released on or before June 2025. Lead Person for Action Item Completion: Miguel A. Padilla Vázquez (Director of Administration)
2022-001
OAE requires the monitoring process of 100% of the population of the subrecipients of federal funds, at least once a year. During the year ended September 30, 2023, the OAE distributed federal funds to 118 subrecipients. However, the subrecipients subjected to formal monitoring were only thirteen (13) or 11%. Cause of Condition: For the year ended September 30, 2023, the OAE had inefficient policies and procedures manuals that prevented the full monitoring of all centers. In order to improve efficiency, the OAE subsequently implemented a new risk assessment in April 2024 that will allow the centers to be monitored in a shorter time. Effect of Condition: The failure to monitor subrecipients may lead to inappropriate use of funds by the subrecipients, and the disallowance of such costs by the federal agencies. Questioned Costs: None. Prior year finding: 2022-002 Recommendation: OAE should review the design of the internal policies according to the available resources and modify what is established in the State Plan regarding the monitoring of subrecipients. The monitoring processes should be designed to ensure that the grants were used properly, and all supporting documents were properly assembled and stored. Best practices on subrecipients monitoring should be searched and evaluated for implementation. View of Responsible Official and Planned Corrective Action Plan: OAE agrees with the finding and will adhere to the corrective action plan on page 39 in this audit report. Responsible Person: Miguel A. Padilla Vázquez-Director of Administration
Show full finding ▾Hide full finding ▴Finding 2023-002: Subrecipient Monitoring Type of Finding: Material Weakness (MW), Instance of Noncompliance (NC) Assistance Listing No.: 93.044, 93.045, 93.053, 93.052 Program Title: Title III - B Supportive Services and Senior Centers, Title III - C Nutrition Services, Nutrition Services Incentive Program, and Title III - E National Family Caregiver Support Federal Award Year: 10/1/2022 - 9/30/2023 Federal Award No.: 2301PROASS, 2301PROACM, 2301PROANS, 2301PROAFC Name of Federal Agency: U.S. Department of Health and Human Services (HHS) Name of Pass-through Entity: N/A Criteria: 45 CFR Sections 1321.11(b) and 1321.17(f)(9), the State Agency is required to develop policies governing all aspects of programs operated under the State Plan and to monitor their implementation, including assessing performance for quality and effectiveness and specifying data system requirements to collect necessary and appropriate data. The policies developed by the State agency shall address the way the State agency will monitor the performance of all programs and activities initiated under this part for quality and effectiveness. Statement of Condition: OAE requires the monitoring process of 100% of the population of the subrecipients of federal funds, at least once a year. During the year ended September 30, 2023, the OAE distributed federal funds to 118 subrecipients. However, the subrecipients subjected to formal monitoring were only thirteen (13) or 11%. Cause of Condition: For the year ended September 30, 2023, the OAE had inefficient policies and procedures manuals that prevented the full monitoring of all centers. In order to improve efficiency, the OAE subsequently implemented a new risk assessment in April 2024 that will allow the centers to be monitored in a shorter time. Effect of Condition: The failure to monitor subrecipients may lead to inappropriate use of funds by the subrecipients, and the disallowance of such costs by the federal agencies. Questioned Costs: None. Prior year finding: 2022-002 Recommendation: OAE should review the design of the internal policies according to the available resources and modify what is established in the State Plan regarding the monitoring of subrecipients. The monitoring processes should be designed to ensure that the grants were used properly, and all supporting documents were properly assembled and stored. Best practices on subrecipients monitoring should be searched and evaluated for implementation. View of Responsible Official and Planned Corrective Action Plan: OAE agrees with the finding and will adhere to the corrective action plan on page 39 in this audit report. Responsible Person: Miguel A. Padilla Vázquez-Director of Administration
The Office updated the policies and procedures regarding the monitoring process for sub-recipients. The implementation of the new strategies for carrying out the Monitoring became effective in April 2024. These are based on Risk Monitoring. They allow us to comply with the number of monitoring sessions required per year and ensure the proper management of federal funds by the sub-recipients. We will continue to carry out the Risk Monitoring sessions strenously to achieve 100% compliance with the required monitoring sessions. Lead Person for Action Item Completion: Miguel A. Padilla Vázquez (Director of Administration)
2022-002
FAC accepted this audit on December 3, 2024 — management decision was due June 3, 2025.
The Office of the Advocate for the Elderly of the Commonwealth of Puerto Rico(OAE) submitted the data collection form for the year ended September 30, 2021, to Federal Clearinghouse after its due date. Also, the current single audit for the year ended September 30, 2022, is being completed and submitted after the corresponding date. Criteria: 2 CFR Part 200, Subpart C, Section 200.512 established that the audit shall be completed and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section shall be submitted within the earlier of 30 days after receipt of the auditor's report(s), or nine months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Unless restricted by law or regulation, the auditee shall make copies available for public inspection. Cause: OAE's Single Audit Report for fiscal year 2021 was submitted on June 27, 2024. The main causes were recurrent delays in engaging the auditors and general planning of the process. For fiscal year 2022, the main causes were the delays experienced in the contract process to engage the external auditors and delays in retrieving the relevant support documents in custody of the Puerto Rico Department of Treasury. All the disbursements are processed by the subject Department. Effect: OAE may be subject to sanction, as described in the Uniform Guidance, Section 225 titled "Sanctions", in cases of continued inability to have an audit conducted in accordance with this part, Federal agencies and pass-through entities shall take appropriate actions using sanctions such as: (a) withholding a percentage of federal award until the audit is completed satisfactorily; (b) withholding or disallowing overhead cost; (c) suspending federal award until the audit is conducted; or (d) terminating the federal award. Questioned Cost: None. Recommendation: We recommend management to formalize a plan to monitor the single audit process, including the engagement of the external auditors, the completion of all required steps, including the access to the required documentation, as well as an itinerary of every relevant step to perform, complete and submit single audit during the required period. Management Response: Management agrees with the observation. Management recognizes that a delay was experienced with respect to 2022. However, Management is working on alternatives to accelerate the process to arrive at full compliance with due dates.
Show full finding ▾Hide full finding ▴Finding Number: 2022-001 Federal Programs: All federal financial assistance programs. Category: Internal Control/Compliance - Material Weakness Compliance Requirement: Reporting - Data Collection Form Condition: The Office of the Advocate for the Elderly of the Commonwealth of Puerto Rico(OAE) submitted the data collection form for the year ended September 30, 2021, to Federal Clearinghouse after its due date. Also, the current single audit for the year ended September 30, 2022, is being completed and submitted after the corresponding date. Criteria: 2 CFR Part 200, Subpart C, Section 200.512 established that the audit shall be completed and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section shall be submitted within the earlier of 30 days after receipt of the auditor's report(s), or nine months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Unless restricted by law or regulation, the auditee shall make copies available for public inspection. Cause: OAE's Single Audit Report for fiscal year 2021 was submitted on June 27, 2024. The main causes were recurrent delays in engaging the auditors and general planning of the process. For fiscal year 2022, the main causes were the delays experienced in the contract process to engage the external auditors and delays in retrieving the relevant support documents in custody of the Puerto Rico Department of Treasury. All the disbursements are processed by the subject Department. Effect: OAE may be subject to sanction, as described in the Uniform Guidance, Section 225 titled "Sanctions", in cases of continued inability to have an audit conducted in accordance with this part, Federal agencies and pass-through entities shall take appropriate actions using sanctions such as: (a) withholding a percentage of federal award until the audit is completed satisfactorily; (b) withholding or disallowing overhead cost; (c) suspending federal award until the audit is conducted; or (d) terminating the federal award. Questioned Cost: None. Recommendation: We recommend management to formalize a plan to monitor the single audit process, including the engagement of the external auditors, the completion of all required steps, including the access to the required documentation, as well as an itinerary of every relevant step to perform, complete and submit single audit during the required period. Management Response: Management agrees with the observation. Management recognizes that a delay was experienced with respect to 2022. However, Management is working on alternatives to accelerate the process to arrive at full compliance with due dates.
As we mentioned in the SA 2021 Corrective Action Plan, WE ARE WORKING WITH Unified Contracts wich is helping us achieve our goal. We will continue with a Unified Contract to ensure that SA 2023 can be released on or before February 2025 and start in 2024 to catch up. We will be working hard to achieve this.
2021-001
OAE requires the monitoring process of 100% of the population of the subrecipients of federal funds, at least once a year. During the year ended September 30, 2022, the OAE distributed federal funds to 123 subrecipients. However, the subrecipients subjected to formal monitoring were only thirteen (13) or 11%. Criteria: 45 CFR Sections 1321.11(b) and 1321.17(f)(9), the State Agency is required to develop policies governing all aspects of programs operated under the State Plan and to monitor their implementation, including assessing performance for quality and effectiveness and specifying data system requirements to collect necessary and appropriate data. The policies developed by the State agency shall address the manner in which the State agency will monitor the performance of all programs and activities initiated under this part for quality and effectiveness. Cause: For the year ended September 30, 2022, the OAE had not yet reviewed the design of its policies for the monitoring activities over subrecipients. These policies do not consider that there are no current or contemplated resources that could be available to perform formal and comprehensive monitoring exercises over the total population of sub-recipients on an annual basis. Effect: The failure to monitor sub-recipients may lead to inappropriate use of the funds by the subrecipients, and the disallowance of such costs by the federal agencies. Questioned Cost: None. Recommendation: OAE should review the design of the internal policies according to the available resources and modify what is established in the State Plan regarding the monitoring of subrecipients. The monitoring processes should be designed to ensure that the grants were used properly, and all supporting documents were properly assembled and stored. Best practices on subrecipients monitoring should be searched and evaluated for implementation. Management Response: Management agrees with the observation. OAE reviewed its policies and procedures for subrecipients monitoring and developed and adopted a risk base plan to comply with the requirements. The subject plan was adopted for implementation effective April 23, 2024. Under the new plan, the monitoring activities will entail a risk-based monitoring approach to streamline the related processes. The benefits of the implementation of new policies will be reviewed starting during the year ending September 30, 2024.
Show full finding ▾Hide full finding ▴Finding Number 2022-002 Federal programs: AL No.: 93.044 Special Programs for the Aging-Title III, Part B-Grants for Supportive Services and Senior Centers AL No.: 93.045 Special Programs for the Aging-Title III, Part C-Nutrition Services Category: Internal Control/Compliance Material Weakness Compliance Requirement: Subrecipient Monitoring Condition: OAE requires the monitoring process of 100% of the population of the subrecipients of federal funds, at least once a year. During the year ended September 30, 2022, the OAE distributed federal funds to 123 subrecipients. However, the subrecipients subjected to formal monitoring were only thirteen (13) or 11%. Criteria: 45 CFR Sections 1321.11(b) and 1321.17(f)(9), the State Agency is required to develop policies governing all aspects of programs operated under the State Plan and to monitor their implementation, including assessing performance for quality and effectiveness and specifying data system requirements to collect necessary and appropriate data. The policies developed by the State agency shall address the manner in which the State agency will monitor the performance of all programs and activities initiated under this part for quality and effectiveness. Cause: For the year ended September 30, 2022, the OAE had not yet reviewed the design of its policies for the monitoring activities over subrecipients. These policies do not consider that there are no current or contemplated resources that could be available to perform formal and comprehensive monitoring exercises over the total population of sub-recipients on an annual basis. Effect: The failure to monitor sub-recipients may lead to inappropriate use of the funds by the subrecipients, and the disallowance of such costs by the federal agencies. Questioned Cost: None. Recommendation: OAE should review the design of the internal policies according to the available resources and modify what is established in the State Plan regarding the monitoring of subrecipients. The monitoring processes should be designed to ensure that the grants were used properly, and all supporting documents were properly assembled and stored. Best practices on subrecipients monitoring should be searched and evaluated for implementation. Management Response: Management agrees with the observation. OAE reviewed its policies and procedures for subrecipients monitoring and developed and adopted a risk base plan to comply with the requirements. The subject plan was adopted for implementation effective April 23, 2024. Under the new plan, the monitoring activities will entail a risk-based monitoring approach to streamline the related processes. The benefits of the implementation of new policies will be reviewed starting during the year ending September 30, 2024.
The Office updated the policies and procedures regarding the monitoring process for sub-recipents. The implementation of the new strategies for carrying out the Moitoring became effective in April 2024. These are based on Risk Monitoring. They allow us to comply with the number of monitoring sessions required per year and ensure the proper management of fedeeral funds by the sub-recipients. We will continue to carry out hte Risk Monigoring sessions to achieve 100% compliance with the required monitoring sessions.
2021-002
FAC accepted this audit on June 27, 2024 — management decision was due December 27, 2024.
The Office of the Advocate for the Elderly of the Commonwealth of Puerto Rico (OAE) submitted the data collection form for the year ended September 30, 2020, to Federal Clearinghouse after its due date. Also, the current single audit for the year ended September 30, 2021, is being completed and submitted after the corresponding date. Criteria: 2 CFR Part 200, Subpart C, Section 200.512 established that the audit shall be completed and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section shall be submitted within the earlier of 30 days after receipt of the auditor's report(s), or nine months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Unless restricted by law or regulation, the auditee shall make copies available for public inspection. Cause: OAE's Single Audit Report for fiscal year 2020 was submitted on January 12, 2023. The main causes were recurrent delays in engaging the auditors and general planning of the process and the extended disruptions caused by COVID-19. For fiscal year 2021, the main causes were the delays experienced in the contract process to engage the external auditors and delays in retrieving the relevant support documents in custody of the Puerto Rico Department of Treasury. All the disbursements are processed by the subject Department. Effect: OAE may be subject to sanction, as described in the Uniform Guidance, Section 225 titled "Sanctions", in cases of continued inability to have an audit conducted in accordance with this part, Federal agencies and pass-through entities shall take appropriate actions using sanctions such as: (a) withholding a percentage of federal award until the audit is completed satisfactorily; (b) withholding or disallowing overhead cost; (c) suspending federal award until the audit is conducted; or (d) terminating the federal award. Questioned Cost: None. Recommendation: We recommend management to formalize a plan to monitor the single audit process, including the engagement of the external auditors, the completion of all required steps, including the access to the required documentation, as well as an itinerary of every relevant step to perform, complete and submit single audit during the required period. Management Response: Management agrees with the observation. Management recognizes that a delay will be experienced with respect to 2021. However, Management adopted a plan to reduce the delay for 2022 and to comply with the deadlines for the years after 2022.
Show full finding ▾Hide full finding ▴Finding Number: 2021-001 Federal Programs: All federal financial assistance programs. Category: Internal Control/Compliance - Material Weakness Compliance Requirement: Reporting - Data Collection Form Condition: The Office of the Advocate for the Elderly of the Commonwealth of Puerto Rico (OAE) submitted the data collection form for the year ended September 30, 2020, to Federal Clearinghouse after its due date. Also, the current single audit for the year ended September 30, 2021, is being completed and submitted after the corresponding date. Criteria: 2 CFR Part 200, Subpart C, Section 200.512 established that the audit shall be completed and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section shall be submitted within the earlier of 30 days after receipt of the auditor's report(s), or nine months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Unless restricted by law or regulation, the auditee shall make copies available for public inspection. Cause: OAE's Single Audit Report for fiscal year 2020 was submitted on January 12, 2023. The main causes were recurrent delays in engaging the auditors and general planning of the process and the extended disruptions caused by COVID-19. For fiscal year 2021, the main causes were the delays experienced in the contract process to engage the external auditors and delays in retrieving the relevant support documents in custody of the Puerto Rico Department of Treasury. All the disbursements are processed by the subject Department. Effect: OAE may be subject to sanction, as described in the Uniform Guidance, Section 225 titled "Sanctions", in cases of continued inability to have an audit conducted in accordance with this part, Federal agencies and pass-through entities shall take appropriate actions using sanctions such as: (a) withholding a percentage of federal award until the audit is completed satisfactorily; (b) withholding or disallowing overhead cost; (c) suspending federal award until the audit is conducted; or (d) terminating the federal award. Questioned Cost: None. Recommendation: We recommend management to formalize a plan to monitor the single audit process, including the engagement of the external auditors, the completion of all required steps, including the access to the required documentation, as well as an itinerary of every relevant step to perform, complete and submit single audit during the required period. Management Response: Management agrees with the observation. Management recognizes that a delay will be experienced with respect to 2021. However, Management adopted a plan to reduce the delay for 2022 and to comply with the deadlines for the years after 2022.
As we mentioned in the SA 2020 Corrective Action Plan, we expected to finish SA 2021 in FY 2023, as well as SA 2022. We were not able to achieve this goal as face-to-face work had not yet been fully normalized due to a Pandemic Covid-19.Normality in terms of face-to-face work was fully implemented in 2022-2023. We currently have a contract to achieve the SA 2022 which will start in April 2024. We will continue to enter into a unified contract to achieve SA 2023 and SA 2024 completion on or before December 31, 2024. We have worked hard planning for this goal.
2020-001
OAE requires the monitoring process of 100% of the population of the subrecipients of federal funds, at least once a year. During the year ended September 30, 2021, the OAE distributed federal funds to 123 subrecipients. However, the subrecipients subjected to formal monitoring were only six (6) or 5%. Criteria: 45 CFR Sections 1321.11(b) and 1321.17(f)(9), the State Agency is required to develop policies governing all aspects of programs operated under the State Plan and to monitor their implementation, including assessing performance for quality and effectiveness and specifying data system requirements to collect necessary and appropriate data. The policies developed by the State agency shall address the manner in which the State agency will monitor the performance of all programs and activities initiated under this part for quality and effectiveness. Cause: The design of the policies for the monitoring activities over subrecipients does not consider that there are no current or contemplated resources that could be available to perform formal and comprehensive monitoring exercises over the total population of sub-recipients on an annual basis. Effect: The failure to monitor sub-recipients may lead to inappropriate use of the funds by the subrecipients, and the disallowance of such costs by the federal agencies. Questioned Cost: None. Recommendation: OAE should review the design of the internal policies according to the available resources and modify what is established in the State Plan regarding the monitoring of subrecipients. The monitoring processes should be designed to ensure that the grants were used properly, and all supporting documents were properly assembled and stored. Best practices on subrecipients monitoring should be searched and evaluated for implementation. Management Response: Management agrees with the observation. OAE reviewed its policies and procedures for subrecipients monitoring and developed and adopted a risk base plan to comply with the requirements. The subject plan was adopted for implementation effective April 23, 2024. Under the new plan, the monitoring activities will entail a risk-based monitoring approach to streamline the related processes.
Show full finding ▾Hide full finding ▴Finding Number 2021-002 Federal programs: AL No.: 93.044 Special Programs for the Aging-Title III, Part B-Grants for Supportive Services and Senior Centers AL No.: 93.045 Special Programs for the Aging-Title III, Part C-Nutrition Services Category: Internal Control/Compliance Material Weakness Compliance Requirement: Subrecipient Monitoring Condition: OAE requires the monitoring process of 100% of the population of the subrecipients of federal funds, at least once a year. During the year ended September 30, 2021, the OAE distributed federal funds to 123 subrecipients. However, the subrecipients subjected to formal monitoring were only six (6) or 5%. Criteria: 45 CFR Sections 1321.11(b) and 1321.17(f)(9), the State Agency is required to develop policies governing all aspects of programs operated under the State Plan and to monitor their implementation, including assessing performance for quality and effectiveness and specifying data system requirements to collect necessary and appropriate data. The policies developed by the State agency shall address the manner in which the State agency will monitor the performance of all programs and activities initiated under this part for quality and effectiveness. Cause: The design of the policies for the monitoring activities over subrecipients does not consider that there are no current or contemplated resources that could be available to perform formal and comprehensive monitoring exercises over the total population of sub-recipients on an annual basis. Effect: The failure to monitor sub-recipients may lead to inappropriate use of the funds by the subrecipients, and the disallowance of such costs by the federal agencies. Questioned Cost: None. Recommendation: OAE should review the design of the internal policies according to the available resources and modify what is established in the State Plan regarding the monitoring of subrecipients. The monitoring processes should be designed to ensure that the grants were used properly, and all supporting documents were properly assembled and stored. Best practices on subrecipients monitoring should be searched and evaluated for implementation. Management Response: Management agrees with the observation. OAE reviewed its policies and procedures for subrecipients monitoring and developed and adopted a risk base plan to comply with the requirements. The subject plan was adopted for implementation effective April 23, 2024. Under the new plan, the monitoring activities will entail a risk-based monitoring approach to streamline the related processes.
As established in the SA 2020 Corrective Action Plan, the OPPEA established a process to adapt to the reality of the office. The OPPEA implemented a Risk Assessment System. The actions taken by management regarding monitoring are based on a review of the policies and processes to carry out the monitoring of subrecipients. Risk monitoring will be carried out to minimize evaluation efforts in the follow-up. With the purpose of streamlining their process and ensuring that they are completed effectively in less time. Some Risk categories were established so that in the event that a Monitor finds as a result of its evaluation that said project represents a risk in the management of funds, a more in-depth Monitoring can be carried out.
2020-002
FAC accepted this audit on January 12, 2023 — management decision was due July 12, 2023.
OAE submitted the data collection form for the year ended September 30, 2018 to Federal Clearinghouse after its due date. Also, the current single audit for the year ended September 30, 2019 is being completed and submitted after the corresponding date. Criteria: 2 CFR Part 200, Subpart C, Section 200.512 established that the audit shall be completed and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section shall be submitted within the earlier of 30 days after receipt of the auditor's report(s), or nine months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Unless restricted by law or regulation, the auditee shall make copies available for public inspection. Cause: OAE's Single Audit Report for fiscal year 2019 was submitted on January 20, 2022. The main cause was attributed to a delay in the engagement of the external auditors for the subject year, and the audit was significantly disrupted by the COVID-19 pandemic. In the case of the fiscal year 2020, the main causes were recurrent delays in the engagement of the auditors and the general planning of the process and the extended disruptions of COVID-19. Effect: OAE may be subject to sanction, as described in the Uniform Guidance, Section 225 titled "Sanctions", in cases of continued inability to have an audit conducted in accordance with this part, Federal agencies and pass-through entities shall take appropriate actions using sanctions such as: (a) withholding a percentage of federal award until the audit is completed satisfactorily; (b) withholding or disallowing overhead cost; (c) suspending federal award until the audit is conducted; or (d) terminating the federal award. Questioned Cost: None. Recommendation: We recommend management to formalize a plan to monitor the full single audit process, including the engagement of the external auditors, the completion of all required steps, including closings, compilation and access to the required documentation, as well as an itinerary of every relevant step to perform, complete and submit single audit during the required period. Also, an adoption of stronger policies to comply with the requirements. Management Response: Management agrees with the observation. Management recognizes that a delay will be experienced with respect to 2021. However, Management will adopt a plan to reduce the delay for 2021 and to comply with the deadlines for the years after 2021.
Show full finding ▾Hide full finding ▴Finding Number: 2020-001 Federal Programs: All federal financial assistance programs. Category: Internal Control/Compliance - Material Weakness Compliance Requirement: Reporting - Data Collection Form Condition: OAE submitted the data collection form for the year ended September 30, 2018 to Federal Clearinghouse after its due date. Also, the current single audit for the year ended September 30, 2019 is being completed and submitted after the corresponding date. Criteria: 2 CFR Part 200, Subpart C, Section 200.512 established that the audit shall be completed and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section shall be submitted within the earlier of 30 days after receipt of the auditor's report(s), or nine months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Unless restricted by law or regulation, the auditee shall make copies available for public inspection. Cause: OAE's Single Audit Report for fiscal year 2019 was submitted on January 20, 2022. The main cause was attributed to a delay in the engagement of the external auditors for the subject year, and the audit was significantly disrupted by the COVID-19 pandemic. In the case of the fiscal year 2020, the main causes were recurrent delays in the engagement of the auditors and the general planning of the process and the extended disruptions of COVID-19. Effect: OAE may be subject to sanction, as described in the Uniform Guidance, Section 225 titled "Sanctions", in cases of continued inability to have an audit conducted in accordance with this part, Federal agencies and pass-through entities shall take appropriate actions using sanctions such as: (a) withholding a percentage of federal award until the audit is completed satisfactorily; (b) withholding or disallowing overhead cost; (c) suspending federal award until the audit is conducted; or (d) terminating the federal award. Questioned Cost: None. Recommendation: We recommend management to formalize a plan to monitor the full single audit process, including the engagement of the external auditors, the completion of all required steps, including closings, compilation and access to the required documentation, as well as an itinerary of every relevant step to perform, complete and submit single audit during the required period. Also, an adoption of stronger policies to comply with the requirements. Management Response: Management agrees with the observation. Management recognizes that a delay will be experienced with respect to 2021. However, Management will adopt a plan to reduce the delay for 2021 and to comply with the deadlines for the years after 2021.
See Corrective Action Plan for table
2019-001
During our compliance procedures, we noted that the procedures of the OAE requires a monitoring process of the total 100% population of the subrecipients of federal funds at least once a year. We observed that during the year ended September 30, 2020, the OAE distributed federal funds to 123 subrecipients. The actual subrecipients subjected to formal monitoring exercises amounted to four (4) or 3%. Criteria: 45 CFR Sections 1321.11(b) and 1321.17(f)(9), the State Agency is required to develop policies governing all aspects of programs operated under the State Plan and to monitor their implementation, including assessing performance for quality and effectiveness and specifying data system requirements to collect necessary and appropriate data. The policies developed by the State agency shall address the manner in which the State agency will monitor the performance of all programs and activities initiated under this part for quality and effectiveness. Cause: The design of the policies for the monitoring activities over subrecipients does not consider that there are no current or contemplated resources that could be available to perform formal and comprehensive monitoring exercises over the total population of sub-recipients on an annual basis. Effect: The failure to monitor sub-recipients may lead to inappropriate use of the funds by the subrecipients, and the disallowance of such costs by the federal agencies. Questioned Cost: None. Recommendation: OAE should review the design of the internal policies according to the available resources and modify what is established in the State Plan regarding the monitoring of subrecipients. The monitoring processes should be designed to ensure that the grants were used properly, and all supporting documents were properly assembled and stored. Best practices on subrecipients monitoring should be searched and evaluated for implementation. Management Response: Management agrees with the observation. OAE is in the process of reviewing its policies and procedures for subrecipients monitoring to develop an effective plan to comply with the requirements.
Show full finding ▾Hide full finding ▴Finding Number 2020-002 Federal programs: CFDA No. 93.044 Special Programs for the Aging-Title III, Part B-Grants for Supportive Services and Senior Centers CFDA No. 93045 Special Programs for the Aging Title III, Part C-Nutrition Services Category: Internal Control/Compliance ? Material Weakness Compliance Requirement: Subrecipient Monitoring Condition: During our compliance procedures, we noted that the procedures of the OAE requires a monitoring process of the total 100% population of the subrecipients of federal funds at least once a year. We observed that during the year ended September 30, 2020, the OAE distributed federal funds to 123 subrecipients. The actual subrecipients subjected to formal monitoring exercises amounted to four (4) or 3%. Criteria: 45 CFR Sections 1321.11(b) and 1321.17(f)(9), the State Agency is required to develop policies governing all aspects of programs operated under the State Plan and to monitor their implementation, including assessing performance for quality and effectiveness and specifying data system requirements to collect necessary and appropriate data. The policies developed by the State agency shall address the manner in which the State agency will monitor the performance of all programs and activities initiated under this part for quality and effectiveness. Cause: The design of the policies for the monitoring activities over subrecipients does not consider that there are no current or contemplated resources that could be available to perform formal and comprehensive monitoring exercises over the total population of sub-recipients on an annual basis. Effect: The failure to monitor sub-recipients may lead to inappropriate use of the funds by the subrecipients, and the disallowance of such costs by the federal agencies. Questioned Cost: None. Recommendation: OAE should review the design of the internal policies according to the available resources and modify what is established in the State Plan regarding the monitoring of subrecipients. The monitoring processes should be designed to ensure that the grants were used properly, and all supporting documents were properly assembled and stored. Best practices on subrecipients monitoring should be searched and evaluated for implementation. Management Response: Management agrees with the observation. OAE is in the process of reviewing its policies and procedures for subrecipients monitoring to develop an effective plan to comply with the requirements.
See Corrective Action Plan for table
2019-002
FAC accepted this audit on January 19, 2022 — management decision was due July 19, 2022.
OAE submitted the data collection form for the year ended September 30, 2018 to Federal Clearinghouse after its due date. Also, the current single audit for the year ended September 30, 2019 is being completed and submitted after the corresponding date. Criteria: 2 CFR Part 200, Subpart C, Section 200.512 established that the audit shall be completed and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section shall be submitted within the earlier of 30 days after receipt of the auditor's report(s), or nine months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Unless restricted by law or regulation, the auditee shall make copies available for public inspection. Cause: OAE's Single Audit Report for fiscal year 2018 was submitted on August 20, 2020. The main cause was attributed to a delay in the engagement of the external auditors for the subject year. The engagement was delayed by a decision of the Governor of Puerto Rico to cancel any existing contract with those former external auditors. In the case of the fiscal year 2019, the engagement of the external auditors was delayed, and the audit was significantly disrupted by the COVID-19 pandemic. Effect: OAE may be subject to sanction, as described in the Uniform Guidance, Section 225 titled "Sanctions", in cases of continued inability to have an audit conducted in accordance with this part, Federal agencies and pass-through entities shall take appropriate actions using sanctions such as: (a) withholding a percentage of federal award until the audit is completed satisfactorily; (b) withholding or disallowing overhead cost; (c) suspending federal award until the audit is conducted; or (d) terminating the federal award. Questioned Cost: None. Recommendation: We recommend management to formalize a plan to monitor the full single audit process, including the engagement of the external auditors, the completion of all required steps, including closings, compilation and access to the required documentation, as well as an itinerary of every relevant step to perform, complete and submit single audit during the required period. Management Response: Management agrees with the observation. Management recognizes that a delay will be experienced with respect 2020, because of the COVID-19. However, Management will adopt a plan to reduce the delay for 2020 and to comply with the deadlines for the years after 2020.
Show full finding ▾Hide full finding ▴Federal Programs: All federal financial assistance programs. Category: Internal Control/Compliance - Material Weakness Compliance Requirement: Reporting - Data Collection Form Condition: OAE submitted the data collection form for the year ended September 30, 2018 to Federal Clearinghouse after its due date. Also, the current single audit for the year ended September 30, 2019 is being completed and submitted after the corresponding date. Criteria: 2 CFR Part 200, Subpart C, Section 200.512 established that the audit shall be completed and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section shall be submitted within the earlier of 30 days after receipt of the auditor's report(s), or nine months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Unless restricted by law or regulation, the auditee shall make copies available for public inspection. Cause: OAE's Single Audit Report for fiscal year 2018 was submitted on August 20, 2020. The main cause was attributed to a delay in the engagement of the external auditors for the subject year. The engagement was delayed by a decision of the Governor of Puerto Rico to cancel any existing contract with those former external auditors. In the case of the fiscal year 2019, the engagement of the external auditors was delayed, and the audit was significantly disrupted by the COVID-19 pandemic. Effect: OAE may be subject to sanction, as described in the Uniform Guidance, Section 225 titled "Sanctions", in cases of continued inability to have an audit conducted in accordance with this part, Federal agencies and pass-through entities shall take appropriate actions using sanctions such as: (a) withholding a percentage of federal award until the audit is completed satisfactorily; (b) withholding or disallowing overhead cost; (c) suspending federal award until the audit is conducted; or (d) terminating the federal award. Questioned Cost: None. Recommendation: We recommend management to formalize a plan to monitor the full single audit process, including the engagement of the external auditors, the completion of all required steps, including closings, compilation and access to the required documentation, as well as an itinerary of every relevant step to perform, complete and submit single audit during the required period. Management Response: Management agrees with the observation. Management recognizes that a delay will be experienced with respect 2020, because of the COVID-19. However, Management will adopt a plan to reduce the delay for 2020 and to comply with the deadlines for the years after 2020.
FINDING NUMBER: #2019-001 AUDITOR'S DESCRIPTION: Internal Control & Compliance - Material Weakness- Reporting CONDITION: OAE submitted the data collection form for the year ended September 30, 2018 to Federal Clearinghouse after its due date. Also, the current single audit for the year ended September 30, 2019 is being completed and submitted after the corresponding date. CORRECTIVE ACTION PLAN: The Single Audit Report for fiscal year 2018 was submitted on August 20, 2020. The main cause was attributed to a delay in the engagement of the external auditors for the subject year. The engagement was delayed by a decision of the Governor of Puerto Rico to cancel any existing contract with those former external auditors. In the case of the fiscal year 2019, the engagement of the external auditors was delayed, and the audit was significantly disrupted by the COVID-19 pandemic. Our Agency will be starting the SA 2020 soon. We will be taking the necessary measures to achieve its completion and to be able to comply with the issuance of the SA to the Clearing House. LEAD PERSON FOR ACTION ITEM COMPLETION: Director of Administration
2018-001
During our compliance procedures, we noted that the procedures of the OAE requires a monitoring process of the total 100% population of the subrecipients of federal funds at least once a year. We observed that during the year ended September 30, 2019, the OAE distributed federal funds to 123 subrecipients. The actual subrecipients subjected to formal monitoring exercises amounted to twenty-four (24) or 20%. Criteria: 45 CFR Sections 1321.11(b) and 1321.17(f)(9), the State Agency is required to develop policies governing all aspects of programs operated under the State Plan and to monitor their implementation, including assessing performance for quality and effectiveness and specifying data system requirements to collect necessary and appropriate data. The policies developed by the State agency shall address the manner in which the State agency will monitor the performance of all programs and activities initiated under this part for quality and effectiveness. Cause: The design of the policies for the monitoring activities over subrecipients does not consider that there are no current or contemplated resources that could be available to perform formal and comprehensive monitoring exercises over the total population of sub-recipients on an annual basis. Effect: The failure to monitoring sub-recipients may lead to inappropriate use of the funds by the subrecipients, and the disallowance of such costs by the federal agencies. Questioned Cost: None. Recommendation: OAE should review the design of the internal policies according to the available resources and modify what is established in the State Plan regarding the monitoring of subrecipients. The monitoring processes should be designed to ensure that the grants were used properly, and all supporting documents were properly assembled and stored. Best practices on subrecipients monitoring should be searched and evaluated for implementation. Management Response: Management agrees with the observation. OAE will review its policies and procedures for subrecipients monitoring to develop an effective plan to comply with the requirements.
Show full finding ▾Hide full finding ▴Finding Number 2019-002 Federal programs: CFDA No.: 93.044 Special Programs for the Aging-Title III, Part B-Grants for Supportive Services and Senior Centers CFDA No.: 93.045 Special Programs for the Aging-Title III, Part C-Nutrition Services Category: Internal Control/Compliance ? Material Weakness Compliance Requirement: Subrecipient Monitoring Condition: During our compliance procedures, we noted that the procedures of the OAE requires a monitoring process of the total 100% population of the subrecipients of federal funds at least once a year. We observed that during the year ended September 30, 2019, the OAE distributed federal funds to 123 subrecipients. The actual subrecipients subjected to formal monitoring exercises amounted to twenty-four (24) or 20%. Criteria: 45 CFR Sections 1321.11(b) and 1321.17(f)(9), the State Agency is required to develop policies governing all aspects of programs operated under the State Plan and to monitor their implementation, including assessing performance for quality and effectiveness and specifying data system requirements to collect necessary and appropriate data. The policies developed by the State agency shall address the manner in which the State agency will monitor the performance of all programs and activities initiated under this part for quality and effectiveness. Cause: The design of the policies for the monitoring activities over subrecipients does not consider that there are no current or contemplated resources that could be available to perform formal and comprehensive monitoring exercises over the total population of sub-recipients on an annual basis. Effect: The failure to monitoring sub-recipients may lead to inappropriate use of the funds by the subrecipients, and the disallowance of such costs by the federal agencies. Questioned Cost: None. Recommendation: OAE should review the design of the internal policies according to the available resources and modify what is established in the State Plan regarding the monitoring of subrecipients. The monitoring processes should be designed to ensure that the grants were used properly, and all supporting documents were properly assembled and stored. Best practices on subrecipients monitoring should be searched and evaluated for implementation. Management Response: Management agrees with the observation. OAE will review its policies and procedures for subrecipients monitoring to develop an effective plan to comply with the requirements.
FINDING NUMBER: #2019-002 AUDITOR'S CONDITION: Internal Control & Compliance - Material Weakness - Sub-recipient Monitoring CONDITION: During our compliance procedures, we noted that the procedures of the OAE requires a monitoring process of the total 100% population of the subrecipients of federal funds at least once a year. We observed that during the year ended September 30, 2019, the OAE distributed federal funds to 123 subrecipients. The actual subrecipients subjected to formal monitoring exercises amounted twenty-four (24) or 20%. CORRECTIVE ACTION PLAN: We will be reviewing the policies and procedures for subrecipients monitoring to develop an effective plan to meet the requirements. LEAD PERSON FOR ACTION ITEM COMPLETION: Internal Auditing Office.
2018-002
FAC accepted this audit on August 19, 2020 — management decision was due February 19, 2021.
GSA_MIGRATION
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2017-001
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GSA_MIGRATION
2017-001
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2017-002
GSA_MIGRATION
Show full finding ▾Hide full finding ▴FAC accepted this audit on April 2, 2019 — management decision was due October 2, 2019.
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2016-001
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2016-002
FAC accepted this audit on May 8, 2018 — management decision was due November 8, 2018.
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2015-002
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2015-003
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