Nebraska Children & Families Foundation

Noncompliance and Significant Deficiency in Internal Controls over Compliance for Reporting Identification data: U.S. Department of Health and Human Services (HHS) – CCDF Cluster, Child Care and Development Block Grant, Assistance Listing No. 93.575, Agreement Identifying No. 2301NECCDD. Criteria: As stated in subaward No. 2301NECCDD signed with the pass-through grantor, Nebraska Department of Health and Human Services (NE DHHS), the Foundation was required to submit two semi-annual work plan activity reports to NE DHHS utilizing the reporting template provided by NE DHHS. Condition: The Foundation did not submit one of the two semi-annual workplans as required. Cause: A breakdown in the Foundation’s internal controls over reporting did not allow the Foundation to meet the reporting requirements of the program. Effect or potential effect: The control deficiency is a significant deficiency that prevented the Foundation from complying with the requirements of the program. Identification of a Repeat Finding: New finding. Recommendation: The Foundation should review its system of internal control over reporting to determine improvements that can be made to ensure the Foundation has processes for remaining in compliance with all reporting criteria identified above. Views of Responsible Officials: To ensure reports are submitted on time to the reporting agency from Nebraska Children and Families Foundation, the Foundation will: 1) All (sub)awards will by reviewed by the Program Lead responsible for deliverables included in the (sub)award agreement. All requirements, including but not limited to reporting requirements, will also be sent to the Program Lead’s supervisor for approval. 2) If necessary, reporting requirements are shared with the contracts and legal department. 3) The Program Lead will complete the required reports before they are due to the awarding agency and sent to their supervisor. 4) The supervisor will review and approve the reports. The supervisor will return with approval or indicate the revision needed. 5) Upon final approval, the Program Lead, or appropriate staff, will submit the report to the awarding agency before the deadline and copy the transmission to their supervisor. 6) The Program Lead will archive the report on the Foundation’s secure data storage site.

2019 - 001 Identification data: U.S. Department of Health and Human Services, Pregnancy Assistance Fund Program, CFDA No. 93.500, Passed through the Nebraska Department of Health and Human Services, Grant Agreement No. SP1AH000056, Award Periods August 1, 2018 through June 30, 2019 and July 1, 2019 through June 30, 2020 and John H. Chafee Foster Care Program for Successful Transition to Adulthood, CFDA No. 93.674, Passed through the Nebraska Department of Health and Human Services, Grant Agreement No. G-1801NECILP, Award Period October 1, 2018 through September 30, 2019 and G-1901NECILP, Award Period October 1, 2019 through September 30, 2020. Criteria: 45 CFR ?75.213 restricts awards, subawards and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Nebraska Children and Families Foundation?s system of internal control over suspension and debarment includes verifying the status of contractors, community providers, consultants, and other lower-tier agencies upon contract execution and payment. Condition: The Organization did not maintain documentation to support the verification that contractors, community providers, consultants, and other lower-tier agencies were not excluded from participation in the Federal grant programs. Cause: A breakdown in the Organization?s internal controls over suspension and debarment did not allow the Organization to maintain adequate documentation to support suspension and debarment verifications. Effect or potential Effect: The Organization may have awarded a contract and/or made payments to a contractor, community provider, consultant, or other lower-tier agency who was excluded from participation in the Federal grant programs. Recommendation: The Organization should review its system of internal controls over suspension and debarment to determine improvements that can be made to ensure adequate documentation is maintained to evidence the Organization?s verifications that contractors, community providers, consultants, and other lower-tier agencies participating in the Federal grant programs are not on the excluded parties list. Responsible Official?s Response: Management of Nebraska Children and Families Foundation understands the need to maintain adequate documentation supporting verifications of suspension and debarment status of contractors, community providers, consultants, and other lower-tier agencies performing services under the Federal grant programs. Management has implemented a process to maintain the verification documentation upon payment or contract execution or renewal with applicable organizations.