Open Recommendations

Reinforce the New Jersey Small Business Development Center’s adherence to requirements on allowable types of hospitality cost under 13 CFR § 130.465 and Program Terms and Conditions, Section 7. Compare the $8,217 in unallowable costs to any overmatch funds per 13 CFR § 130.450(g) and recover costs as appropriate.

Instruct the New Jersey SBDC to submit an updated budget that reflects the $420,700 impact of the service center closure to evaluate whether funds are allowable in accordance with 2 CFR § 200.308(c)(5)(7).

Update the SBA resource partner website to reflect active New Jersey Small Business Development Center service centers.

Instruct the New Jersey Small Business Development Center to reconcile $75,247 of program income across the network to ensure generated income and expenses are accounted for and reported accurately in accordance with 13 CFR § 130.480.

Enforce the requirement for the New Jersey Small Business Development Center to timely adhere to export certification requirements and regularly report on its compliance status to SBA in accordance with Notice of Funding Section 5.1.4.4.

Ensure the New Jersey Small Business Development Center is maintaining sufficient accessibility to its facilities and appropriate staff levels and notifying clients of service centers’ hours of operation in accordance with 15 USC § 648(c)(2).

Ensure the New Jersey Small Business Development Center implements a process to ensure all personnel funded by federal grant funds are notified of their whistleblower protection rights in accordance with 41 U.S.C § 4712.

Ensure the New Jersey Small Business Development Center relates financial data and program accomplishments toward meeting the performance goals for the entire performance period as 2 CFR § 200.329(b) requires.

Ensure ICE staff respond to all detainee requests within the required 3 business days.

Rec. 1.a: The DoD OIG recommended that the Partner for Tronconi Segarra & Associates, LLP direct the auditors to perform and document audit procedures to test the internal controls over the Cash Management and Special Tests and Provisions compliance requirements.

Rec. 1.b: The DoD OIG recommended that the Partner for Tronconi Segarra & Associates, LLP direct the auditors to perform and document additional audit procedures to determine whether CUBRC Inc.'s internal controls over equipment requirements are operating effectively and its compliance with the Equipment requirement.

Rec. 1.c: The DoD OIG recommended that the Partner for Tronconi Segarra & Associates, LLP direct the auditors to perform and document additional audit procedures to determine CUBRC Inc.'s compliance with the Period of Performance requirement.

Rec. 1.d: The DoD OIG recommended that the Partner for Tronconi Segarra & Associates, LLP direct the auditors to select additional procurement transactions that align with the sample size guidelines of the American Institute of Certified Public Accountants, perform audit procedures on the selected transactions, and document the procedures to provide sufficient, appropriate evidence on the internal controls and compliance with the Procurement requirements.

Rec. 1.e: The DoD OIG recommended that the Partner for Tronconi Segarra & Associates, LLP direct the auditors to coordinate with CUBRC, Inc. to obtain a revised schedule of expenditures of Federal awards, prepared in accordance with 2 C.F.R. Part 200 (Uniform Guidance), and perform procedures to ensure that the revised schedule of expenditures of Federal awards is appropriate and complete

Rec. 1.f: The DoD OIG recommended that the Partner for Tronconi Segarra & Associates, LLP direct the auditors to update the FY 2022 single audit report of CUBRC, Inc. with the results of the additional audit procedures the auditors perform in response to Recommendations 1.a, 1.b, 1.c, 1.d, and 1.e.

Rec. 1.g: The DoD OIG recommended that the Partner for Tronconi Segarra & Associates, LLP direct the auditors to prepare audit documentation in future single audits to identify the relevant internal controls for each direct and material compliance requirement, identify the internal controls the auditors plan to test, and document the sampling plan in accordance with the sampling guidelines of the American Institute of Certified Public Accountants.

Develop and implement a policy that clearly defines roles and responsibilities for Office of Multifamily Housing Programs' staff for EBLL-related requirements, including the oversight of property owners' compliance with these requirements.

Establish processes to track reported EBLLs for the Office of Multifamily Housing Programs to easily identify the status of owners' remediation efforts for units that were the source of the confirmed EBLL.

Rec. 1: The DoD OIG recommended that the U.S. Property and Fiscal Officer for the Nevada National Guard issue a memorandum to the auditors assigned to the Internal Review Division emphasizing that when auditors do not comply with Generally Accepted Government Auditing Standards requirements, the auditors should take the following actions in accordance with Generally Accepted Government Auditing Standards 2.19 and 9.05. a. Assess the significance of noncompliance to the engagement objectives. b. Document the assessment, along with the reasons for not following the requirement. c. Determine which type of Generally Accepted Government Auditing Standards compliance statement to use. d…

Rec. 2: The DoD OIG recommended that the U.S. Property and Fiscal Officer for the Nevada National Guard develop and implement a process for the monitoring and documentation of quality in their office in accordance with Generally Accepted Government Auditing Standards 5.43 and 5.44.

Rec. 3: The DoD OIG recommended that the U.S. Property and Fiscal Officer for the Nevada National Guard require that auditors assigned to the Internal Review Division obtain training on performing nonaudit services in accordance with Generally Accepted Government Auditing Standards.

Rec. 4: The DoD OIG recommended that the National Guard Bureau Internal Review Office Director issue a memorandum to the auditors at the National Guard Bureau Internal Review Office Headquarters and the Internal Review divisions of the United States Property and Fiscal Office to emphasize the requirement to inquire of the audited entity's management whether any investigations or legal proceedings significant to the audit objectives have been initiated or are in process with respect to the period under audit, in accordance with Generally Accepted Government Auditing Standard 8.27.

Rec. 5: The DoD OIG recommended that the National Guard Bureau Internal Review Office Headquarters Director and U.S. Property and Fiscal Officer for the Maryland National Guard develop and implement a tool, such as a fraud risk assessment template, to help ensure that the auditors assess the risk of fraud that is significant in the context of the audit objectives, in accordance with Generally Accepted Government Auditing Standard 8.71.

Rec. 6: The DoD OIG recommended that the National Guard Bureau Internal Review Director develop and implement a tool, such as an independence tracking checklist, to assist auditors at the Internal Review Headquarters office with ensuring that all supervisors and auditors assigned to an engagement complete a statement of independence before starting the engagement.

Rec. 7: The DoD OIG recommended that the National Guard Bureau Internal Review Office Director develop and implement a tool, such as a reporting checklist, that includes a step to verify that each audit report includes the appropriate GAGAS compliance statement in accordance with Generally Accepted Government Auditing Standards 2.17 and 9.03.