YMCA of Greater San Antonio

Section III. Federal Award Findings and Questioned Costs 2024-001 – Reporting Information on Federal Program – Assisting Listing Number 21.027, U.S. Department of the Treasury, Coronavirus State and Local Fiscal Recovery Funds – American Rescue Plan Act Criteria or Specific Requirement – According to 2 CFR Part 200.512, auditees are required to submit the audit reporting package, including the Single Audit report, to the Federal Audit Clearinghouse within 30 days after receipt of the auditor’s report(s), or nine months after the end of the audit period, whichever comes first. Condition – The auditee did not submit the audit reporting package for the fiscal year ended December 31, 2023 within the required time frame. The Single Audit report was submitted to the Federal Audit Clearinghouse on April 4, 2025, which is beyond the required deadline of September 30, 2024. Questioned Costs: $0 Context: The reporting package was submitted 186 days past the deadline. Cause - The delay was due to a lack of effective internal controls and oversight to ensure timely submission of the audit reporting package. Effect or Potential Effect - Late submission of the audit reporting package may result in non-compliance with federal requirements, potentially affecting the auditee’s eligibility for future federal funding and subjecting the auditee to increased scrutiny or penalties. Recommendation - We recommend that the YMCA establish and implement a formal process to monitor and ensure timely submission of the audit reporting package to the Federal Audit Clearinghouse. This process should include setting internal deadlines and assigning responsibility to specific personnel for compliance monitoring. Views of Responsible Officials – Management has reviewed the finding related to the late filing of the audit report to the Federal Audit Clearinghouse and has developed the following plan to address this finding and ensure compliance going forward: 1. Root Cause Analysis – Previous to 2023, the last time the YMCA was required to have a Single Audit was the year ended December 31, 2012. Because this was a new process to the YMCA, we were unaware that we needed to submit the Single Audit to the Federal Audit Clearinghouse. In past years, the independent audit firm initiated the e-filing process on our behalf. 2. Action Steps – The YMCA will develop a year-end Federal Awards checklist to include all necessary preparation steps including but not limited to preparation of the Schedule of Expenditures of Federal Awards (SEFA); corresponding audit documentation; and procedures for filing the completed Single Audit to the Federal Audit Clearinghouse including confirmation that independent auditors have reviewed and certified the submission to the Clearinghouse. 3. Responsible Parties – The Controller will complete the checklist and perform the filing to the Federal Audit Clearinghouse and the CFO will review and approve. 4. Timeline – Submission of the Single Audit to the Federal Audit Clearinghouse as well as completion, review, and approval of the checklist will be done within 30 days of receipt of the final Single Audit report. 5. Monitoring & Evaluation – The checklist and approval process will be monitored on an annual basis to ensure ongoing compliance and effectiveness of this corrective action plan.

Information on Federal Program(s) - U.S. Department of the Treasury, Coronavirus State and Local Fiscal Recovery Funds American Rescue Plan Act – Youth Mental Health ALN 21-027 Award Year 2023 Criteria or Specific Requirement – The Code of Federal Regulations Section 200.403 states that for costs to be allowable under Federal awards, they must be a in accordance with the terms and conditions of the federal award. Condition – During our audit, we identified instances where overtime costs were charged to the federal award without documented pre-approval for these overtime expenses in the grant document or approved budget. During our testing of payroll disbursements, we noted the following exceptions: Two of the 11 expenditures sampled included unauthorized overtime pay in the amount of $391. Cause - Policies and procedures were not appropriately adhered to in certain instances to ensure that supporting documentation was maintained correctly to evidence that costs were allowable and that an appropriate level of review and approval was completed prior to charging costs to a federal program. Effect or Potential Effect - The effect of charging unauthorized overtime costs to the federal award is the potential disallowance of these costs upon review by the grantor agency, which could result in the organization having to refund these amounts to the federal government. Additionally, this finding raises concerns about the adequacy of the organization's internal controls over compliance with federal award requirements. Questioned Costs - $391 Context – We tested a sample of 11 items and found two exceptions as noted in the condition in the amount of $391. This is a condition identified per review of YMCA’s compliance with specified requirements using a statistically valid sample. Recommendation - We recommend that YMCA: 1) Review and strengthen its internal controls and procedures to ensure that all costs charged to federal awards, especially personnel costs, are in accordance with the terms and conditions of the award and applicable federal regulations. 2) Provide training to relevant staff on the requirements for charging costs to federal awards, with a particular focus on the need for prior approval for overtime charges.3) Work with the federal grantor agency to resolve the questioned costs and take any necessary corrective actions to prevent similar findings in the future. Views of Responsible Officials – Management has reviewed the finding related to charging overtime pay to the federal award and has developed the following plan to address this finding and ensure compliance going forward: 1. The Y has already addressed the disallowed costs with the City of San Antonio and will be deducting those costs from the next quarterly billing on June 20, 2024. 2. Due to accounting staff turnover throughout 2023, our new staff will be attending online trainings offered through the City’s online funding portal before the next billing on June 20, 2024. 3. Knowledge gained by staff through a monitoring visit by the City in January 2024 has provided additional direction as to what expenditures are qualified under the provisions of the federal award. Staff will utilize knowledge gained from this visit to ensure certain components of compensation are excluded from future billings. 4. The Y will develop an invoicing checklist for use by the Senior Accountant that will assist her with ensuring that only approved budgeted expenditures are included in future billings. This checklist will be completed by the Senior Accountant and reviewed and signed by the VPFinance/ Controller before invoice submission to the City.