NORTHWEST COLORADO COUNCIL OF GOVERNMENTS

EIN: 840639906

UEI: RQC9GY7Z15J7

10
Audit Years
8
Total Findings
3
Repeat Findings

FY 2023-12-31

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on July 30, 2024. 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 January 30, 2025, which was (566 days ago).

What is a management decision? →
2023-001
Cost Allowability
REPEAT
Condition

Federal Agency: Department of Housing and Urban Development Federal Program Title: Community Development Block Grants Assistance Listing Number: 14.228 Federal Award Identification Number and Year: B-21-DC-08-0001 2021 Pass-Through Agency: Colorado Department of Local Affairs Pass-Through Number: F20CDBG20630 Award Period: April 1, 2020 – March 31, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter Criteria or Specific Requirement: In accordance with the requirements of Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance), the Council should report all federal expenditures in the schedule of expenditures of federal awards (SEFA) each fiscal year. Additionally, per 2 CFR section 200.502(a)-(d), the determination of when a federal award is expended must be based on when the activity related to the federal award occurs, including the value of new loans made during the audit period. Condition: In reviewing the expenditure detail and supporting documentation for the 2023 SEFA, the Council included $150,000 of excess federal expenditures that were not disbursed in 2023. Questioned Costs: None Context: The inclusion of excess expenditures to be reported in 2024 was identified during completeness testing of the current year major program. Cause: SEFA expenditures for the CDBG program were not reconciled to loan disbursements in 2023. Management misinterpreted the loan amount report provided by NLF’s loan management software. One loan for $150,000 was disbursed during 2023 and another $150,000 loan was disbursed to the same borrower in 2024. However, all $300,000 was initially reported on the 2023 SEFA. Effect: The 2023 SEFA was initially overstated by $150,000, and was subsequently adjusted. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2022-003. Recommendation: We recommend that the Council record federal expenditures on the SEFA under the program in the year upon which the loan disbursement occurs using the proper report from NLF’s loan management software. Views of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

Community Development Block Grants – Assistance Listing No. 14.228 Recommendation: We recommend that the Council record federal expenditures on the SEFA under the program in the year upon which the loan disbursement occurs using the proper report from NLF’s loan management software. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Fiscal Office will work with the Program Director to ensure the proper report is used to identify actual loan disbursements, rather than agreed upon loan amounts, if different, for future SEFA preparation. Name(s) of the contact person(s) responsible for corrective action: Anita Cameron, NLF Director and Becky Walter, Finance Director Planned completion date for corrective action plan: December 31, 2024

Prior Finding References

2022-003

About Allowable Costs / Cost Principles →
2023-002
Cost Allowability
REPEATQUESTIONED COSTS
Condition

Federal Agency: Department of Energy Federal Program Title: Weatherization Assistance for Low-income Persons Assistance Listing Number: 81.042 Federal Award Identification Number and Year: DEEE0007908-2017 2019 Pass-Through Agency: Colorado Energy Office Pass-Through Number: GAE 20-2019 Award Period: July 1, 2019 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires charges to federal awards for salaries and wages be based on records that accurately reflect the work performed. These records must be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: One hourly employee’s wages were overpaid and charged to the grant when compared to the hours per the approved timesheet. Questioned Costs: $46 Context: For one employee, and one pay period tested, the hourly employee’s gross wages overpaid and overcharged to the grant by $46 based on two hours that were improperly included in the final payroll run. Cause: Entering payroll into QuickBooks using the approved timesheet for hourly employees was a manual process. For this individual, the timesheet reported a total of 92 hours of regular pay. However, when the time sheet hours were summed, it was noted there were only 90 hours reported on the time sheet, thus 2 hours were improperly included on the payroll run as hour totals were not verified. Effect: For the February 15, 2023, pay period, the employee was overpaid, and the grant was overcharged a total of $46. Repeat Finding: The finding is a repeat of a finding in the 2021 fiscal. Prior year finding number was 2021-002. Recommendation: We recommend the Council review its payroll procedures over hourly employees to ensure all hours are properly accounted for by pay code in the final payroll. Views of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

Weatherization Assistance for Low Income Persons – Assistance Listing No. 81.042 Recommendation: We recommend the Council review its payroll procedures over hourly employees to ensure all hours are properly accounted for by pay code in the final payroll. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: the NWCCOG Energy Program transitioned to an electronic timesheet system that automatically calculates total hours. The implementation of this system eliminates the possibility of future occurrences. Name(s) of the contact person(s) responsible for corrective action: Elaina West, Finance Manager Planned completion date for corrective action plan: December 31, 2024

Prior Finding References

2021-002

About Allowable Costs / Cost Principles →

FY 2022-12-31

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on July 24, 2023. 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 January 24, 2024, which was (938 days ago).

What is a management decision? →
2022-002
Reporting
Condition

Federal Agency: Department of Housing and Urban Development Federal Program Title: Community Development Block Grants Assistance Listing Number: 14.228 Federal Award Identification Number and Year: B-22-DC-08-0001 - 2022 Pass-Through Agency: Colorado Department of Local Affairs Pass-Through Number: F16CDB16602 Award Period: April 1, 2020 ? March 31, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of reporting. The Council should have internal controls designed to ensure compliance with those provisions. Condition: The Council did not prepare performance reports in 2022. Questioned Costs: None Context: In testing the Community Development Block Grants (CDBG) program, the online portal for submitting reimbursement requests and reports has not been working since August 2022. However, the required performance reports were not being prepared by program personnel in the meantime. Cause: Performance reports were not being prepared because the portal was not functioning. Effect: The lack of preparation of performance reports provides an opportunity for noncompliance. Repeat Finding: No Recommendation: We recommend preparing the required reports under the CDBG program to be ready for uploading to the portal once it is accessible to ensure reporting requirements are met. Views of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

Community Development Block Grants ? Assistance Listing No. 14.228 Recommendation: We recommend preparing the required reports under the CDBG program to be ready for uploading to the portal once it is accessible to ensure reporting requirements are met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Program Director will work with the Fiscal Office to ensure all reporting requirements are met prior to the deadline, regardless of ability to submit. This plan will ensure past, current, and future reporting requirements are met. Name(s) of the contact person(s) responsible for corrective action: Anita Cameron, NLF Director and Becky Walter, Fiscal Manager Planned completion date for corrective action plan: December 31, 2023

About Reporting →
2022-003
Cost Allowability
Condition

Federal Agency: Department of Housing and Urban Development Federal Program Title: Community Development Block Grants Assistance Listing Number: 14.228 Federal Award Identification Number and Year: B-21-DC-08-0001 - 2021 Pass-Through Agency: Colorado Department of Local Affairs Pass-Through Number: F16CDB16602 Award Period: April 1, 2020 ? March 31, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter Criteria or Specific Requirement: In accordance with the requirements of Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance), the Council should report all federal expenditures in the schedule of expenditures of federal awards (SEFA) each fiscal year. Additionally, per 2 CFR section 200.502(a)-(d), the determination of when a federal award is expended must be based on when the activity related to the federal award occurs, including the value of new loans made during the audit period. Condition: In reviewing the expenditure detail and supporting documentation for the 2022 SEFA, the Council had omitted approximately $726,000 of federal expenditures from the 2021 SEFA that were expended as part of the loan program in 2021. These loans were included in the SEFA for 2022 and audited as a major program for 2022. Questioned Costs: Unknown Context: The omission of expenditures from the 2021 SEFA was identified during testing of the current year major program. The seven omitted loans from 2021 were include in the 2022 loan activity for testing. Cause: In 2022, requests for reimbursement were submitted for certain loans distributed in 2021 that were not reflected on the 2021 SEFA. Effect: Excluding program expenditures from the SEFA results in the Council being out of compliance with the requirements of individual grant agreements and the Uniform Grant Guidance. Repeat Finding: No Recommendation: We recommend that the Council record federal expenditures on the SEFA under the program in the year upon which the loan disbursement occurs. Views of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

Community Development Block Grants ? Assistance Listing No. 14.228 Recommendation: We recommend that the Council record federal expenditures on the SEFA under the program in the year upon which the loan disbursement occurs. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Council has revised their procedures so that loan disbursements will be recorded on the SEFA in the year in which they are disbursed. Name(s) of the contact person(s) responsible for corrective action: Anita Cameron, NLF Director, and Becky Walter, Fiscal Manager Planned completion date for corrective action plan: December 31, 2023

About Allowable Costs / Cost Principles →
2022-004
Cost Allowability
REPEAT
Condition

Federal Agency: Department of Health and Human Services Federal Program Title: Aging Cluster Assistance Listing Number: 93.AGING Federal Award Identification Number and Year: 2101COSSC6-00 - 2021 Pass-Through Agency: Colorado Department of Human Services Pass-Through Number: None provided Award Period: February 1, 2021 ? September 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires charges to federal awards for salaries and wages be based on records that accurately reflect the work performed. These records must be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: One hourly employee?s wages was underpaid and were not charged to the grant when compared to the hours per the approved timesheet. Questioned Costs: None Context: For one payroll transaction of five tested, the hourly employee?s gross wages were underpaid and undercharged to the grant by $128 based on four hours that were improperly omitted from final payroll. Cause: Entering payroll into QuickBooks using the approved timesheet for hourly employees is a manual process. For this individual, the timesheet reported 84 hours of regular pay and four hours of paid staff leave. Four regular pay hours were improperly omitted from the hours paid as these were misinterpreted to be the four hours of paid hourly staff leave. Effect: For the June 30, 2022 pay period, the employee was underpaid, and the grant was undercharged a total of $128. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2021-002. Recommendation: We recommend the Council review its payroll procedures over hourly employees to ensure all hours are properly accounted for by pay code in the final payroll. Views of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

AGING CLUSTER ? Assistance Listing No. 93.AGING Recommendation: We recommend the Council review its payroll procedures over hourly employees to ensure all hours are properly accounted for by pay code in the final payroll. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Fiscal staff will review timesheet formats and search for possible improvements to the existing templates. Since this incident occurred, the Council has split the former Fiscal Coordinator position into two separate roles. This allows each employee to spend additional time on a fewer number of employees during payroll and review each timesheet with a high level of detail. Fiscal staff will continue to focus on precautions to reduce risk of error and employees will be encouraged to review their paystubs after each pay period. Name(s) of the contact person(s) responsible for corrective action: Becky Walter, Fiscal Manager Planned completion date for corrective action plan: December 31, 2023

Prior Finding References

2021-002

About Allowable Costs / Cost Principles →

FY 2021-12-31

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on October 2, 2022. 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 April 2, 2023, which was (1235 days ago).

What is a management decision? →
2021-002
Other
Condition

2021 ? 002 Federal Agency: Department of Energy Federal Program Title: Weatherization Assistance for Low Income Persons Assistance Listing Number: 81.042 Pass-Through Agency: Colorado Department of Local Affairs Pass-Through Number: Award Period: July 1, 2019 - June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter Criteria or Specific Requirement: Per 2 CFR Part 200 and Uniform Grant Guidance (UGG), charges to federal awards for salaries and wages must by based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: From a sample of forty payroll disbursements, one expenditure was not supported by the employee?s approved rate of pay and hours charged to the grant. Questioned Costs: None Context: One of the forty samples resulted in auditor calculated wages exceeding wages charged to the grant, which is an error rate of 2.5%. Cause: One employee?s approved rate of pay was not updated for all applicable pay codes. Effect: For the period January 1, 2021 through February 15, 2021, the employee was underpaid and the grant was undercharged a total of $20.67. The amount of $20.67 was paid to the employee and recorded to the grant in fiscal year 2022 after the issue was identified during audit fieldwork. Repeat Finding: No Recommendation: We recommend the Council review its procedures for updating approved pay rates to ensure all pay codes are appropriately updated within the Council?s system. Views of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

Department of Energy Northwest Colorado Council of Governments respectfully submits the following corrective action plan for the year ended December 31, 2021. Audit period: December 31, 2021 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS DEPARTMENT OF ENERGY 2021-002: Weatherization Assistance for Low Income Persons ? Assistance Listing No. 81.042 Recommendation: We recommend the Council review its procedures for updating approved pay rates to ensure all pay codes are appropriately updated with the Council?s system. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: the Council reviewed its procedures for updating approved pay rates to ensure all pay codes are appropriately updated within the Council?s system. Name(s) of the contact person(s) responsible for corrective action: Jon Stavney, Executive Director, and Becky Walter, Fiscal Manager Planned completion date for corrective action plan: December 2022 If the Department of Energy has questions regarding this plan, please call Becky Walter at 970-468-0295.

About Other →

FY 2018-12-31

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on March 9, 2020. 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 September 9, 2020, which was (2170 days ago).

What is a management decision? →
2018-001
Other
Condition

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Other →

FY 2017-12-31

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on May 30, 2018. 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 November 30, 2018, which was (2819 days ago).

What is a management decision? →
2017-001
Activities Allowed or Unallowed / Cost Allowability
Condition

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →

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