El Paso Hispanic Chamber of CommerceNon-Profit

2021-004 ? Deficiency in Cash Management Controls over Compliance ? Significant Deficiency Federal Program Information Funding Agency: U.S. Department of Commerce, Minority Business Development Agency Federal Award Agreement Number: Not Applicable Award Year: 2021 Title: MBDA Business Center CFDA Number: 11.805 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - The Entity does not have policies in procedures to ensure bank reconciliations are being performed on a timely basis and reviewed and approved by someone other than the person preparing. Criteria - 2 CFR section 200.303 ? Internal Controls of the Uniform Guidance states that the nonfederal entity must: (a) Establish and maintain effective internal controls over 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). Questioned Costs - Not applicable. Effect - Bank reconciliations not performed on a timely manner may not detect misstatements or errors. Cause - The Entity does not have proper controls in place to verify federal funds are received for the amount requested on a timely basis or retain detailed support reconciliations are being performed. Auditors? Recommendation - The Auditor recommends that the Entity implement adequate controls for the bank reconciliation process to ensure the reconciliation is occurring on a timely basis and is reviewed by someone other than the preparer.

2021‐004 – Deficiency in Cash Management Controls over Compliance – Significant Deficiency Federal Program Information Funding Agency: U.S. Department of Commerce, Minority Business Development Agency Federal Award Agreement Number: Not Applicable Award Year: 2021 Title: MBDA Business Center CFDA Number: 11.805 Pass‐through Agency: Not Applicable, Direct Program Pass‐through Identification Number: Not Applicable, Direct Program Condition ‐ The Entity does not have policies in procedures to ensure bank reconciliations are being performed on a timely basis and reviewed and approved by someone other than the person preparing. Criteria ‐ 2 CFR section 200.303 – Internal Controls of the Uniform Guidance states that the nonfederal entity must: (a) Establish and maintain effective internal controls over 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). Questioned Costs ‐ Not applicable. Effect ‐ Bank reconciliations not performed on a timely manner may not detect misstatements or errors. Cause ‐ The Entity does not have proper controls in place to verify federal funds are received for the amount requested on a timely basis or retain detailed support reconciliations are being performed.

2021-005 ? Deficiency in Special Tests and Provision Controls over Compliance with Training ? Significant Deficiency Federal Program Information Funding Agency: U.S. Department of Commerce, Minority Business Development Agency Federal Award Agreement Number: Not Applicable Award Year: 2021 Title: MBDA Business Center CFDA Number: 11.805 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - The Entity was unable to provide support to test controls over compliance over training. Criteria ? 2 CFR section 200.303 ? Internal Controls of the Uniform Guidance states that the nonfederal entity must: (a) Establish and maintain effective internal controls over 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). Questioned Costs - Not applicable. Effect - The Entity may unintentionally miss a required training which could lead to repayment of funds. Cause - The Entity is not following its policy to ensure all mandatory training is completed as needed. Auditors? Recommendation - The Auditor recommends the Entity follow their employee policies and procedures related to mandatory trainings and retain documentation of all mandatory trainings held.

2021‐005 – Deficiency in Special Tests and Provision Controls over Compliance with Training – Significant Deficiency Federal Program Information Funding Agency: U.S. Department of Commerce, Minority Business Development Agency Federal Award Agreement Number: Not Applicable Award Year: 2021 Title: MBDA Business Center CFDA Number: 11.805 Pass‐through Agency: Not Applicable, Direct Program Pass‐through Identification Number: Not Applicable, Direct Program Condition ‐ The Entity was unable to provide support to test controls over compliance over training. Criteria – 2 CFR section 200.303 – Internal Controls of the Uniform Guidance states that the nonfederal entity must: (a) Establish and maintain effective internal controls over 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). Questioned Costs ‐ Not applicable. Effect ‐ The Entity may unintentionally miss a required training which could lead to repayment of funds. Cause ‐ The Entity is not following its policy to ensure all mandatory training is completed as needed.

2021-006 ? Deficiencies in Activities Allowed, Allowable Costs, and Period of Performance Controls over Compliance with Payroll ? Significant Deficiency Federal Program Information Funding Agency: U.S. Department of Commerce, Minority Business Development Agency Federal Award Agreement Number: Not Applicable Award Year: 2021 Title: MBDA Business Center CFDA Number: 11.805 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - During our review of payroll related transactions, the following were noted ? For 5 of the 40 payroll transactions tested, the employee did not have an approved timesheet or time and effort available for the pay period. ? For 3 of the 40 payroll transactions tested, no timesheet or other record of hours worked was available to support hours paid for the pay period. ? For 1 of the 40 payroll transactions tested, employee was not paid for all hours worked on timesheet. Criteria ? 2 CFR section 200.303 ? Internal Controls of the Uniform Guidance states that the nonfederal entity must: (a) Establish and maintain effective internal controls over 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). Per 2 CFR section 200.430 ? Compensation ? personal services, paragraph (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Questioned Costs ?$1,010 Effect - The Entity may unintentionally expense employee?s salary out of the federal grant that does not qualify or under/over compensate what is applicable for the work performed by that employee. This could lead to questioned costs and repayment of funds to the Grantor agency. Cause - The Entity does not have proper controls in place to verify that documentation was maintained to indicate the employees? time paid under the federal grant. Controls were put in place during the year but were not consistently followed. Auditors? Recommendation - The Auditor recommends that the Entity implement controls for documenting and retaining information to indicate the Entity follows the requirements over 2 CFR section 200.430(i), and that all pay rates be reviewed for approval and propriety.

2021‐006 – Deficiencies in Activities Allowed, Allowable Costs, and Period of Performance Controls over Compliance with Payroll – Significant Deficiency Federal Program Information Funding Agency: U.S. Department of Commerce, Minority Business Development Agency Federal Award Agreement Number: Not Applicable Award Year: 2021 Title: MBDA Business Center CFDA Number: 11.805 Pass‐through Agency: Not Applicable, Direct Program Pass‐through Identification Number: Not Applicable, Direct Program Condition ‐ During our review of payroll related transactions, the following were noted  For 5 of the 40 payroll transactions tested, the employee did not have an approved timesheet or time and effort available for the pay period.  For 3 of the 40 payroll transactions tested, no timesheet or other record of hours worked was available to support hours paid for the pay period.  For 1 of the 40 payroll transactions tested, employee was not paid for all hours worked on timesheet. Criteria – 2 CFR section 200.303 – Internal Controls of the Uniform Guidance states that the nonfederal entity must: (a) Establish and maintain effective internal controls over 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). Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Questioned Costs –$1,010 Effect ‐ The Entity may unintentionally expense employee’s salary out of the federal grant that does not qualify or under/over compensate what is applicable for the work performed by that employee. This could lead to questioned costs and repayment of funds to the Grantor agency. Cause ‐ The Entity does not have proper controls in place to verify that documentation was maintained to indicate the employees’ time paid under the federal grant. Controls were put in place during the year but were not consistently followed.

2021-007 ? Deficiency in Reporting Controls over Compliance with Financial Reporting ? Significant Deficiency Federal Program Information Funding Agency: U.S. Department of Commerce, Minority Business Development Agency Federal Award Agreement Number: Not Applicable Award Year: 2021 Title: MBDA Business Center CFDA Number: 11.805 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - The Entity was unable to provide the annual SF-424A or provide support it was submitted on a timely basis. All other reporting under the program was submitted timely and accurately. Criteria ? 2 CFR section 200.303 ? Internal Controls of the Uniform Guidance states that the nonfederal entity must: (a) Establish and maintain effective internal controls over 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). Questioned Costs - Not applicable. Effect - Not submitting an accurate annual report due on a timely basis could result in disallowed costs. Cause - The Entity did not have sufficient controls in place to ensure all reporting is submitted to the grantor agency accurately and on a timely basis, and to retain documentation of the reporting. Auditors? Recommendation - The Auditor recommends adequate controls are implemented to provide assurance that reports are submitted on a timely basis.

2021‐007 – Deficiency in Reporting Controls over Compliance with Financial Reporting – Significant Deficiency Federal Program Information Funding Agency: U.S. Department of Commerce, Minority Business Development Agency Federal Award Agreement Number: Not Applicable Award Year: 2021 Title: MBDA Business Center CFDA Number: 11.805 Pass‐through Agency: Not Applicable, Direct Program Pass‐through Identification Number: Not Applicable, Direct Program Condition ‐ The Entity was unable to provide the annual SF‐424A or provide support it was submitted on a timely basis. All other reporting under the program was submitted timely and accurately. Criteria – 2 CFR section 200.303 – Internal Controls of the Uniform Guidance states that the nonfederal entity must: (a) Establish and maintain effective internal controls over 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). Questioned Costs ‐ Not applicable. Effect ‐ Not submitting an accurate annual report due on a timely basis could result in disallowed costs. Cause ‐ The Entity did not have sufficient controls in place to ensure all reporting is submitted to the grantor agency accurately and on a timely basis, and to retain documentation of the reporting.

2021-004 ? Deficiency in Cash Management Controls over Compliance ? Significant Deficiency Federal Program Information Funding Agency: U.S. Department of Commerce, Minority Business Development Agency Federal Award Agreement Number: Not Applicable Award Year: 2021 Title: MBDA Business Center CFDA Number: 11.805 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - The Entity does not have policies in procedures to ensure bank reconciliations are being performed on a timely basis and reviewed and approved by someone other than the person preparing. Criteria - 2 CFR section 200.303 ? Internal Controls of the Uniform Guidance states that the nonfederal entity must: (a) Establish and maintain effective internal controls over 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). Questioned Costs - Not applicable. Effect - Bank reconciliations not performed on a timely manner may not detect misstatements or errors. Cause - The Entity does not have proper controls in place to verify federal funds are received for the amount requested on a timely basis or retain detailed support reconciliations are being performed. Auditors? Recommendation - The Auditor recommends that the Entity implement adequate controls for the bank reconciliation process to ensure the reconciliation is occurring on a timely basis and is reviewed by someone other than the preparer.

2021‐004 – Deficiency in Cash Management Controls over Compliance – Significant Deficiency Federal Program Information Funding Agency: U.S. Department of Commerce, Minority Business Development Agency Federal Award Agreement Number: Not Applicable Award Year: 2021 Title: MBDA Business Center CFDA Number: 11.805 Pass‐through Agency: Not Applicable, Direct Program Pass‐through Identification Number: Not Applicable, Direct Program Condition ‐ The Entity does not have policies in procedures to ensure bank reconciliations are being performed on a timely basis and reviewed and approved by someone other than the person preparing. Criteria ‐ 2 CFR section 200.303 – Internal Controls of the Uniform Guidance states that the nonfederal entity must: (a) Establish and maintain effective internal controls over 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). Questioned Costs ‐ Not applicable. Effect ‐ Bank reconciliations not performed on a timely manner may not detect misstatements or errors. Cause ‐ The Entity does not have proper controls in place to verify federal funds are received for the amount requested on a timely basis or retain detailed support reconciliations are being performed.

2021-005 ? Deficiency in Special Tests and Provision Controls over Compliance with Training ? Significant Deficiency Federal Program Information Funding Agency: U.S. Department of Commerce, Minority Business Development Agency Federal Award Agreement Number: Not Applicable Award Year: 2021 Title: MBDA Business Center CFDA Number: 11.805 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - The Entity was unable to provide support to test controls over compliance over training. Criteria ? 2 CFR section 200.303 ? Internal Controls of the Uniform Guidance states that the nonfederal entity must: (a) Establish and maintain effective internal controls over 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). Questioned Costs - Not applicable. Effect - The Entity may unintentionally miss a required training which could lead to repayment of funds. Cause - The Entity is not following its policy to ensure all mandatory training is completed as needed. Auditors? Recommendation - The Auditor recommends the Entity follow their employee policies and procedures related to mandatory trainings and retain documentation of all mandatory trainings held.

2021‐005 – Deficiency in Special Tests and Provision Controls over Compliance with Training – Significant Deficiency Federal Program Information Funding Agency: U.S. Department of Commerce, Minority Business Development Agency Federal Award Agreement Number: Not Applicable Award Year: 2021 Title: MBDA Business Center CFDA Number: 11.805 Pass‐through Agency: Not Applicable, Direct Program Pass‐through Identification Number: Not Applicable, Direct Program Condition ‐ The Entity was unable to provide support to test controls over compliance over training. Criteria – 2 CFR section 200.303 – Internal Controls of the Uniform Guidance states that the nonfederal entity must: (a) Establish and maintain effective internal controls over 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). Questioned Costs ‐ Not applicable. Effect ‐ The Entity may unintentionally miss a required training which could lead to repayment of funds. Cause ‐ The Entity is not following its policy to ensure all mandatory training is completed as needed.

2021-006 ? Deficiencies in Activities Allowed, Allowable Costs, and Period of Performance Controls over Compliance with Payroll ? Significant Deficiency Federal Program Information Funding Agency: U.S. Department of Commerce, Minority Business Development Agency Federal Award Agreement Number: Not Applicable Award Year: 2021 Title: MBDA Business Center CFDA Number: 11.805 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - During our review of payroll related transactions, the following were noted ? For 5 of the 40 payroll transactions tested, the employee did not have an approved timesheet or time and effort available for the pay period. ? For 3 of the 40 payroll transactions tested, no timesheet or other record of hours worked was available to support hours paid for the pay period. ? For 1 of the 40 payroll transactions tested, employee was not paid for all hours worked on timesheet. Criteria ? 2 CFR section 200.303 ? Internal Controls of the Uniform Guidance states that the nonfederal entity must: (a) Establish and maintain effective internal controls over 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). Per 2 CFR section 200.430 ? Compensation ? personal services, paragraph (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Questioned Costs ?$1,010 Effect - The Entity may unintentionally expense employee?s salary out of the federal grant that does not qualify or under/over compensate what is applicable for the work performed by that employee. This could lead to questioned costs and repayment of funds to the Grantor agency. Cause - The Entity does not have proper controls in place to verify that documentation was maintained to indicate the employees? time paid under the federal grant. Controls were put in place during the year but were not consistently followed. Auditors? Recommendation - The Auditor recommends that the Entity implement controls for documenting and retaining information to indicate the Entity follows the requirements over 2 CFR section 200.430(i), and that all pay rates be reviewed for approval and propriety.

2021‐006 – Deficiencies in Activities Allowed, Allowable Costs, and Period of Performance Controls over Compliance with Payroll – Significant Deficiency Federal Program Information Funding Agency: U.S. Department of Commerce, Minority Business Development Agency Federal Award Agreement Number: Not Applicable Award Year: 2021 Title: MBDA Business Center CFDA Number: 11.805 Pass‐through Agency: Not Applicable, Direct Program Pass‐through Identification Number: Not Applicable, Direct Program Condition ‐ During our review of payroll related transactions, the following were noted  For 5 of the 40 payroll transactions tested, the employee did not have an approved timesheet or time and effort available for the pay period.  For 3 of the 40 payroll transactions tested, no timesheet or other record of hours worked was available to support hours paid for the pay period.  For 1 of the 40 payroll transactions tested, employee was not paid for all hours worked on timesheet. Criteria – 2 CFR section 200.303 – Internal Controls of the Uniform Guidance states that the nonfederal entity must: (a) Establish and maintain effective internal controls over 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). Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Questioned Costs –$1,010 Effect ‐ The Entity may unintentionally expense employee’s salary out of the federal grant that does not qualify or under/over compensate what is applicable for the work performed by that employee. This could lead to questioned costs and repayment of funds to the Grantor agency. Cause ‐ The Entity does not have proper controls in place to verify that documentation was maintained to indicate the employees’ time paid under the federal grant. Controls were put in place during the year but were not consistently followed.

2021-007 ? Deficiency in Reporting Controls over Compliance with Financial Reporting ? Significant Deficiency Federal Program Information Funding Agency: U.S. Department of Commerce, Minority Business Development Agency Federal Award Agreement Number: Not Applicable Award Year: 2021 Title: MBDA Business Center CFDA Number: 11.805 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - The Entity was unable to provide the annual SF-424A or provide support it was submitted on a timely basis. All other reporting under the program was submitted timely and accurately. Criteria ? 2 CFR section 200.303 ? Internal Controls of the Uniform Guidance states that the nonfederal entity must: (a) Establish and maintain effective internal controls over 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). Questioned Costs - Not applicable. Effect - Not submitting an accurate annual report due on a timely basis could result in disallowed costs. Cause - The Entity did not have sufficient controls in place to ensure all reporting is submitted to the grantor agency accurately and on a timely basis, and to retain documentation of the reporting. Auditors? Recommendation - The Auditor recommends adequate controls are implemented to provide assurance that reports are submitted on a timely basis.

2021‐007 – Deficiency in Reporting Controls over Compliance with Financial Reporting – Significant Deficiency Federal Program Information Funding Agency: U.S. Department of Commerce, Minority Business Development Agency Federal Award Agreement Number: Not Applicable Award Year: 2021 Title: MBDA Business Center CFDA Number: 11.805 Pass‐through Agency: Not Applicable, Direct Program Pass‐through Identification Number: Not Applicable, Direct Program Condition ‐ The Entity was unable to provide the annual SF‐424A or provide support it was submitted on a timely basis. All other reporting under the program was submitted timely and accurately. Criteria – 2 CFR section 200.303 – Internal Controls of the Uniform Guidance states that the nonfederal entity must: (a) Establish and maintain effective internal controls over 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). Questioned Costs ‐ Not applicable. Effect ‐ Not submitting an accurate annual report due on a timely basis could result in disallowed costs. Cause ‐ The Entity did not have sufficient controls in place to ensure all reporting is submitted to the grantor agency accurately and on a timely basis, and to retain documentation of the reporting.

2020-001 ? Internal Controls Over Compliance Requirements ? Material Weakness Federal Program Information: Funding Agency: U.S. Department of Treasury Title: Coronavirus Relief Fund CFDA Number: 21.019 Federal Award Identification number N/A Pass Through Entity: City of El Paso, El Paso County Award Year: 2020 Condition: There is no documentation that the program director reviews the request for payments prior to the CFO submitting to the City or County. This affects the activities allowed, allowable costs, period of performance and financial reporting requirements of the program. Criteria: CFR 200.303 requires a non-Federal entity to 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 be in compliance with guidance in ``Standards for Internal Control in the Federal Government?? issued by the Comptroller General of the United States and the ``Internal Control Integrated Framework??, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Questioned costs: None Effect: Failing to meet these requirements could result in noncompliance with grant terms and being liable for any applicable repayment to the granting agency. Cause: The Organization is not implementing appropriate policies and procedures to establish and maintain effective internal controls under the grant to insure compliance. Auditor's Recommendation: The auditor recommends that the Organization re-evaluate their policies and procedures to ensure that internal controls are designed and implemented to ensure compliance with grant requirements. View of Responsible Officials: EPHCC concurs with all of CRI?s findings and recommendations for improvement. EPHCC will work to strengthen its processes as noted in the corrective action plan

2020-002 ? Internal Controls Over Compliance Requirements ? Significant Deficiency Federal Program Information: Funding Agency: U.S. Department of Treasury Title: Coronavirus Relief Fund CFDA Number: 21.019 Federal Award Identification number N/A Pass Through Entity: City of El Paso, El Paso County Award Year: 2020 Condition: The organization was not able to provide proof that performance reporting was reviewed prior to submission to City or County. Criteria: CFR 200.303 requires a non-Federal entity to 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 be in compliance with guidance in ``Standards for Internal Control in the Federal Government?? issued by the Comptroller General of the United States and the ``Internal Control Integrated Framework??, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Questioned costs: None Effect: Failing to meet these requirements could result in noncompliance with grant terms and being liable for any applicable repayment to the granting agency. Cause: The Organization did not retain appropriate documentation to verify that reporting was reviewed prior to submission. Auditor's Recommendation: The auditor recommends that the Organization re-evaluate their policies and procedures to ensure that internal controls are designed and implemented to ensure compliance with grant compliance and that evidence of all submissions required under grants is retained View of Responsible Officials: EPHCC concurs with all of CRI?s findings and recommendations for improvement. EPHCC will work to strengthen its processes as noted in the corrective action plan.

2020-003 ? Internal Controls Over Compliance Requirements ? Significant Deficiency Federal Program Information: Funding Agency: U.S. Department of Treasury Title: Coronavirus Relief Fund CFDA Number: 21.019 Federal Award Identification number N/A Pass Through Entity: City of El Paso, El Paso County Award Year: 2020 Condition: There is no established control over payroll costs charged to the program. Payroll costs have controls in place, however the allocated payroll is not broken out by the hours performed, but rather allocated based on the budgets. This affects the activities allowed, allowable costs, and period of performance requirements of the program. Criteria: CFR 200.303 requires a non-Federal entity to 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 be in compliance with guidance in ``Standards for Internal Control in the Federal Government?? issued by the Comptroller General of the United States and the ``Internal Control Integrated Framework??, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Questioned costs: None Effect: Failing to meet these requirements could result in noncompliance with grant terms and being liable for any applicable repayment to the granting agency. Cause: The Organization is not implementing appropriate policies and procedures to establish and maintain effective internal controls under the grant to insure compliance. Auditor's Recommendation: The auditor recommends that the Organization re-evaluate their policies and procedures to ensure that internal controls are designed and implemented to ensure compliance with grant requirements. View of Responsible Officials: EPHCC concurs with all of CRI?s findings and recommendations for improvement. EPHCC will work to strengthen its processes as noted in the corrective action plan

2019-001 ? Internal Controls over Compliance Requirements ? Material Weakness Federal Program Information: Funding Agency: U.S. Department of Commerce Title: Minority Women?s Enterprise Diversity Center CFDA Number: 11.802 Federal Award Identification number MB18OBD8020080 Pass Through Entity: N/A Award Year: 2018-19 and 2019-20 Condition: There is no documentation that the program director reviews the request for payments, financial reports or budget reviews prior to the CFO submitting to the MBDA. In addition, there is no established control over non-payroll costs charged to the program. Payroll costs have controls in place, however the allocated payroll is not broken out by the hours performed, but rather allocated based on the budgets. This affects the activities allowed, allowable costs, matching, period of performance and financial reporting requirements of the program. Criteria: CFR 200.303 requires a non-Federal entity to 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 be in compliance with guidance in ``Standards for Internal Control in the Federal Government?? issued by the Comptroller General of the United States and the ``Internal Control Integrated Framework??, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Questioned costs: None Effect: Failing to meet these requirements could result in noncompliance of the grant and being liable for any applicable repayment to the granting agency. Cause: The Organization is not implementing appropriate policies and procedures to establish and maintain effective internal controls under the grant to insure compliance. Auditor's Recommendation: The auditor recommends that the Organization re-evaluate their policies and procedures to ensure that internal controls are designed and implemented to ensure compliance with grant requirements. View of Responsible Officials: EPHCC concurs with all of CRI?s findings and recommendations for improvement. EPHCC will work to strengthen its processes as noted in the corrective action plan.

2019-002 ? Internal Controls over Cash Management ? Material Weakness and Material Noncompliance Federal Program Information: Funding Agency: U.S. Department of Commerce Title: Minority Women?s Enterprise Diversity Center CFDA Number: 11.802 Federal Award Identification number MB18OBD8020080 Pass Through Entity: N/A Award Year: 2018-19 and 2019-20 Condition: The organization is not following their own policy to only use advanced payment in isolated incidents when funds are needed immediately. In addition, the advanced funds are not being spent within 10 days of the advance being received per the Organization's policy. At the end of the 2018 fiscal year, the Organization received a grant advance. The amount was not fully used until August 2019. In addition, the Organization requests funds prior to the expenditures being spent each month. This reflects that the Organization is not following their own written procedures, as the reimbursement method is preferred. Criteria: Under 2 CFR section 200.305(b)(1)), ?A non-Federal entity must be paid in advance provided that it maintains, or demonstrates the willingness to maintain, both written procedures that minimize the time elapsing between the transfer of funds from the U.S. Treasury and disbursement by the non-Federal entity, as well as a financial management system that meets the specified standards for fund control and accountability?. The Organization does have written procedures to minimize the time elapsing. Appendix 2:III- Advance Payment Request for Incurred Expenses describes that when EPHCC ?receives advanced payment, the costs will be expended within ten business days of receipt to avoid excess cash on hand?. In addition, the Organization?s Appendix 2:II- Grant Drawdown describes that the advance method should only be used in isolated situations where cash is needed in advance prior to the expenditures being made. Questioned costs: The questioned costs total $23,424. This was determined and computed by taking the advance from the prior year and summing up the over/under each month from the amount requested and the expenditures used until the end of July 2019. It was noted after August 2019, there was no longer an excess of cash on hand. Effect: Failing to meet these requirements could result in noncompliance of the grant and being liable for any applicable repayment to the granting agency. Cause: The Organization is not implementing appropriate policies and procedures to establish and maintain effective internal controls under the grant to insure compliance with cash management. The Organization is not following its written policies and procedures relating to cash management. Auditor's Recommendation: The auditor recommends that the Organization re-evaluate their policies and procedures to ensure that internal controls are designed and implemented to ensure compliance with cash management requirements. View of Responsible Officials: EPHCC concurs with all of CRI?s findings and recommendations for improvement. EPHCC will work to strengthen its processes as noted in the corrective action plan.

2019-003 ? Internal Controls over Activities Allowed and Costs Allowed ? Material Weakness and Material Noncompliance Federal Program Information: Funding Agency: U.S. Department of Commerce Title: Minority Women?s Enterprise Diversity Center CFDA Number: 11.802 Federal Award Identification number MB18OBD8020080 Pass Through Entity: N/A Award Year: 2018-19 and 2019-20 Condition: There were two compliance requirements effected by insufficient documentation. A- Activities Allowed: There were 6 expenditures tested in which the documentation was insufficient to determine whether the activities were allowed. B- Costs Allowed: There were 17 expenditures tested in which the documentation was insufficient to determine whether the costs were allowed. 11 of these expenditures were in regards to the mileage requests forms not having sufficient documentation of what program the mileage belonged to. The sample was not statistically valid. Criteria: 2 CFR 200.403(g) requires that costs charged to federal awards be adequately documented. Supporting documentation is required to be retained to evidence the allowability of amounts charged to federal award programs. Questioned costs: A- Activities Allowed: The exceptions detected totaled $2,254. Likely questioned costs extrapolated from the known questioned costs totaled $24,523. B- Costs Allowed: The exceptions detected totaled $2,880. Likely questioned costs extrapolated from the known questioned costs totaled $27,248. Effect: Failing to meet these requirements could result in noncompliance of the grant and being liable for any applicable repayment to the granting agency. Cause: The Organization is not retaining appropriate documentation to verify the activities or costs are allowed Auditor's Recommendation: The auditor recommends that the Organization re-evaluate their policies and procedures to ensure that internal controls are designed and implemented to ensure compliance with grant compliance. View of Responsible Officials: EPHCC concurs with all of CRI?s findings and recommendations for improvement. EPHCC will work to strengthen its processes as noted in the corrective action plan.