OIG Ca 25 020 Desk Review Of The State Of North Dakota S Use Of Coronavirus Relief Fund Proceeds
Summary
Desk review OIG-CA-25-020, dated December 17, 2024, in which the Department of the Treasury Office of Inspector General transmits a review of the State of North Dakota's use of Coronavirus Relief Fund (CRF) proceeds performed by Castro & Company, LLC. Reviewing a non-statistical selection of 27 transactions, Castro identified ineligible questioned costs of $507,804 and unsupported questioned costs of $204,988, for total questioned costs of $712,792, and rated North Dakota's risk of unallowable use of funds as moderate. The review states that several payment types did not comply with the CARES Act and Treasury guidance. It recommends recoupment or replacement of the questioned amounts, follow-up on the drilled but uncompleted oil well grant program and subscription costs, and a reconciliation supporting a $6,651 interest difference. A schedule of monetary benefits is attached.
Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used
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DEPARTMENT OF THE TREASURY
W ASHINGTON, D.C. 20220
OFFICE OF
INSPECTOR GENERAL
December 17, 2024
MEMORANDUM FOR JESSICA MILANO, CHIEF PROGRAM OFFICER, OFFICE OF
CAPITAL ACCESS, DEPARTMENT OF THE TREASURY
FROM: Deborah L. Harker /s/
Assistant Inspector General for Audit
SUBJECT: Desk Review of the State of North Dakota’s Use of
Coronavirus Relief Fund Proceeds (OIG-CA-25-020)
Please find the attached desk review memorandum 1 on State of North Dakota’s
(North Dakota) use of Coronavirus Relief Fund (CRF) proceeds. The CRF is
authorized under Title VI of the Social Security Act, as amended by Title V,
Division A of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act).
Under a contract monitored by our office, Castro & Company, LLC (Castro), a
certified independent public accounting firm, performed the desk review. Castro
performed the desk review in accordance with the Council of the Inspectors
General on Integrity and Efficiency Quality Standards for Federal Offices of
Inspector General standards of independence, due professional care, and quality
assurance.
In its desk review, Castro personnel reviewed documentation for a non-statistical
selection of 27 transactions reported in the quarterly Financial Progress Reports
(FPR) and identified ineligible and unsupported questioned costs of $507,804 and
$204,988, respectively, resulting in total questioned costs of $712,792 (see
attached schedule of monetary benefits).
Castro determined the expenditures related to the Grants greater than or equal to
$50,000 and the Transfers greater than or equal to $50,000 2 payment types
complied with the CARES Act but did not comply with the Department of the
Treasury’s (Treasury) Guidance. Additionally, Castro found that the Contracts
greater than or equal to $50,000, Direct Payments greater than or equal to $50,000,
1
The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) assigned the Department of
the Treasury Office of Inspector General with responsibility for compliance monitoring and
oversight of the receipt, disbursement, and use of Coronavirus Relief Fund (CRF) payments. The
purpose of the desk review is to perform monitoring procedures of the prime recipient’s receipt,
disbursement, and use of CRF proceeds as reported in the grant-reporting portal on a quarterly
basis.
2
A transfer to another government entity is a disbursement or payment to a government entity
that is legally distinct from the prime recipient.
Page 2
Aggregate Reporting less than $50,000, 3 and Aggregate Payments to Individuals4
payment types did not comply with the CARES Act and Treasury Guidance. Castro
also identified reporting error misclassifications within the Contracts greater than
or equal to $50,000, Grants greater than or equal to $50,000, Transfers greater
than or equal to $50,000, Direct Payments greater than or equal to $50,000,
Aggregate Reporting less than $50,000, and Aggregate Payment to Individuals
payment types. Additionally, Castro determined that North Dakota’s risk of
unallowable use of funds is moderate.
Castro recommends that the Treasury Office of Inspector General (OIG) confirm
the transactions noted as unsupported or ineligible expenditures within the
Contracts greater than or equal to $50,000, Direct Payments greater than or equal
to $50,000, Aggregate Reporting less than $50,000, and Aggregate Payments to
Individuals payment types are recouped or replaced by other eligible
expenditures, not previously charged to CRF, that were incurred during the period
of performance. Based on North Dakota management’s responsiveness to
Treasury OIG’s requests and management’s ability to provide sufficient
documentation, Castro recommends that Treasury OIG determine the feasibility of
conducting an audit for the Contracts greater than or equal to $50,000, Direct
Payments greater than or equal to $50,000, Aggregate Reporting less than
$50,000, and Aggregate Payments to Individuals payment types.
Treasury OIG and Castro met with North Dakota management to discuss the
report. North Dakota management stated they would provide
additional documentation to Treasury OIG to support the questioned costs or
replace them with other eligible expenditures.
At the time of desk review fieldwork, Castro noted that North Dakota had findings
in their Single Audit Act Reports for fiscal years 2021/2022 (combined report).
Castro recommends that Treasury OIG follow-up with Treasury’s Office of Capital
Access to ensure that management decision letters are issued on the findings
identified by the auditor in the Single Audit Act Report, as summarized below:
3 Recipients are required to report CRF transactions greater than or equal to $50,000 in detail in the
grant-reporting portal. Transactions less than $50,000 can be reported as an aggregate lump-sum
amount by type (contracts, grants, loans, direct payments, and transfers to other government
entities).
4 Obligations and expenditures for payments made to individuals, regardless of amount, are
required to be reported in the aggregate in the grant-reporting portal to prevent inappropriate
disclosure of personally identifiable information.
Page 3
• North Dakota’s fiscal year 2020 Single Audit Act Report was published
on March 17, 2021, and the auditor did not identify any unsupported
questioned costs specific to the CRF.
• North Dakota’s fiscal years 2021/2022 Single Audit Act Report was
published on March 29, 2023, and the auditor found unsupported
questioned costs specific to the CRF totaling $617,870.
Castro recommends Treasury OIG follow-up on any CRF specific questioned costs
reported in the fiscal year 2021/2022 Single Audit Act report.
Castro identified other matters throughout the course of the desk review, which
warrant recommendations to Treasury OIG for additional action. Castro made
recommendations related to the following issues:
1) Since Castro identified unsupported questioned costs within the amounts
Castro tested related to the drilled but uncompleted (DUC) oil well grant program,
Castro recommends Treasury OIG determine the feasibility of performing
additional follow-up with North Dakota to determine if there were other instances
of unsupported balances within the DUC oil well grant program;
2) Follow-up with North Dakota management and request that management
performs an analysis over all of their grant-reporting portal balances to determine
if there were other instances of subscription costs that extended past September
30, 2022, in addition to the items found through Castro’s testing; and
3) North Dakota management provided Castro underlying details evidencing
separately tracked CRF interest bearing income accounts within the accounting
system; however, North Dakota’s general ledger did not show how the interest
income was applied to the CRF grant-reporting portal payment types. Castro
recommends Treasury OIG request that North Dakota management conduct a
general ledger detail reconciliation related to the interest income. Based on the
results of this analysis, Castro recommends that Treasury OIG determines if the
analysis supports the $6,651 difference between the interest earned per the
general ledger and the interest claimed in the grant-reporting portal.
In connection with our contract with Castro, we reviewed Castro’s desk review
memorandum and related documentation and inquired of its representatives. Our
review, as differentiated from an audit performed in accordance with generally
accepted government auditing standards, was not intended to enable us to
express an opinion on North Dakota’s use of the CRF proceeds. Castro is
responsible for the attached desk review memorandum and the conclusions
expressed therein. Our review found no instances in which Castro did not comply
in all material respects with Quality Standards for Federal Offices of Inspectors
General.
Page 4
We appreciate the courtesies and cooperation provided to Castro and our staff
during the desk review. If you have any questions or require further information,
please contact me at (202) 486-1420, or a member of your staff may contact Lisa
DeAngelis, Audit Director, at (202) 487-8371.
cc:
Michelle. A. Dickerman, Deputy Assistant General Counsel, Department of
the Treasury
Danielle Christensen, Deputy Chief Program Officer, Office of Capital
Access, Department of the Treasury
Wayne Ference, Partner, Castro & Company, LLC
Joseph Goplin, Director of State Financial Services, State of North Dakota
Page 5
Attachment
Schedule of Monetary Benefits
According to the Code of Federal Regulations, 5 a questioned cost is a cost that is
questioned due to a finding:
(a) which resulted from a violation or possible violation of a statute,
regulation, or the terms and conditions of a Federal award, including for
funds used to match Federal funds;
(b) where the costs, at the time of the review, are not supported by
adequate documentation; or
(c) where the costs incurred appear unreasonable and do not reflect the
actions a prudent person would take in the circumstances.
Questioned costs are to be recorded in the Department of the Treasury’s
(Treasury) Joint Audit Management Enterprise System (JAMES). 6 The amount will
also be included in the Office of Inspector General (OIG) Semiannual Report to
Congress. It is Treasury management's responsibility to report to Congress on the
status of the agreed to recommendations with monetary benefits in accordance
with 5 USC 405.
Recommendation Questioned Costs
Recommendation No. 1 $712,792
The questioned cost represents amounts provided by Treasury under the
Coronavirus Relief Fund. As discussed in the attached desk review, $712,792 is
North Dakota’s total expenditures reported in the grant-reporting portal that were
ineligible or lacked supporting documentation.
5
2 CFR § 200.84 – Questioned Cost
6
JAMES is Treasury’s audit recommendation tracking system.
1635 King Street
Alexandria, VA 22314
Phone: 703.229.4440
Fax: 703.859.7603
www.castroco.com
Desk Review of the State of North Dakota
December 17, 2024
OIG-CA-25-020
MEMORANDUM FOR DEBORAH L. HARKER,
ASSISTANT INSPECTOR GENERAL FOR AUDIT
FROM: Wayne Ference
Partner, Castro & Company, LLC
SUBJECT: Desk Review of the State of North Dakota
On January 25, 2024, we initiated a desk review of the State of North Dakota’s
(North Dakota) use of the Coronavirus Relief Fund (CRF) authorized under Title VI
of the Social Security Act, as amended by Title V, Division A of the Coronavirus
Aid, Relief, and Economic Security Act (CARES Act). 1 The objective of our desk
review was to evaluate North Dakota’s documentation supporting its uses of CRF
proceeds as reported in the GrantSolutions 2 portal and to assess the risk of
unallowable use of funds. The scope of our desk review was limited to obligation
and expenditure data for the period of March 1, 2020 through
September 30, 2023, 3 as reported in the GrantSolutions portal.
As part of our desk review, we performed the following:
1) reviewed North Dakota’s quarterly Financial Progress Reports (FPRs)
submitted in the GrantSolutions portal through September 30, 2023;
2) reviewed the Department of the Treasury’s (Treasury) Coronavirus Relief
Fund Guidance as published in the Federal Register on January 15, 2021; 4
1
P.L. 116-136 (March 27, 2020).
2
GrantSolutions, a grant and program management Federal shared service provider under the
United States (U.S.) Department of Health and Human Services, developed a customized and user-
friendly reporting solution to capture the use of CRF payments from prime recipients.
3
North Dakota fully expended their total CRF proceeds as of September 30, 2023. Castro set the
scope end date to September 30, 2023, which was the date of North Dakota’s last reporting
submission within the GrantSolutions portal.
4
Coronavirus Relief Fund Guidance as published in the Federal Register (January 15, 2021)
https://home.treasury.gov/system/files/136/CRF-Guidance-Federal-Register_2021-00827.pdf
3) reviewed Treasury’s Office of Inspector General (OIG) Coronavirus Relief
Fund Frequently Asked Questions Related to Reporting and
Recordkeeping; 5
4) reviewed Treasury OIG’s monitoring checklists 6 of North Dakota’s quarterly
FPR submissions for reporting deficiencies;
5) reviewed other audit reports issued, such as Single Audit Act reports, 7 and
those issued by the Government Accountability Office and other applicable
Federal agency OIGs for internal control or other deficiencies that may
pose risk or impact North Dakota’s uses of CRF proceeds;
6) reviewed Treasury OIG Office of Investigations, the Council of the
Inspectors General on Integrity and Efficiency Pandemic Response
Accountability Committee, 8 and Treasury OIG Office of Counsel input on
issues that may pose risk or impact North Dakota’s uses of CRF proceeds;
7) interviewed key personnel responsible for preparing and certifying North
Dakota’s GrantSolutions portal quarterly FPR submissions, as well as
officials responsible for obligating and expending CRF proceeds;
5
Department of the Treasury Office of Inspector General Coronavirus Relief Fund Frequently Asked
Questions Related to Reporting and Recordkeeping OIG-20-028R; March 2, 2021.
6
The checklists were used by Treasury OIG personnel to monitor the progress of prime recipient
reporting in the GrantSolutions portal. GrantSolutions quarterly submission reviews were
designed to identify material omissions and significant errors, and where necessary, included
procedures for notifying prime recipients of misreported data for timely correction. Treasury OIG
followed the CRF Prime Recipient Quarterly GrantSolutions Submissions Monitoring and Review
Procedures Guide, OIG-CA-20-029R to monitor the prime recipients on a quarterly basis.
7
P. L. 104-156 (July 5, 1996) The Single Audit Act of 1984, as amended in 1996, requires entities
who receive federal funds in excess of $750,000 to undergo an annual audit of those Federal funds.
The act was enacted for the purpose of promoting sound financial management, including
effective internal controls, with respect to Federal awards administered by non-Federal entities and
to establish uniform requirements for audits. This prime recipient was subject to those audit
requirements, and Castro reviewed applicable prior year single audit reports as part of our desk
review risk assessment procedures.
8
Section 15010 of P.L. 116-136, the CARES Act, established the Pandemic Response Accountability
Committee within the Council of the Inspectors General on Integrity and Efficiency to promote
transparency and conduct and support oversight of covered funds (see Footnote 15 for a definition
of covered funds) and the coronavirus response to (1) prevent and detect fraud, waste, abuse, and
mismanagement; and (2) mitigate major risks that cut across program and agency boundaries.
8) made a non-statistical selection of Contracts, Grants, Transfers, 9 Direct 8F
Payments, Aggregate Reporting, 10 and Aggregate Payments to
9F
Individuals11 data identified through GrantSolutions reporting; and
9) evaluated documentation and records used to support North Dakota’s
quarterly FPRs.
Based on our review of North Dakota’s documentation supporting the uses of its
CRF proceeds as reported in the GrantSolutions portal, we determined that the
expenditures related to the Grants greater than or equal to $50,000 and the
Transfers greater than or equal to $50,000 payment types complied with the
CARES Act but did not comply with Treasury’s Guidance. Additionally, we found
that the Contracts greater than or equal to $50,000, Direct Payments greater than
or equal to $50,000, Aggregate Reporting less than $50,000, and Aggregate
Payments to Individuals payment types did not comply with the CARES Act and
Treasury’s Guidance. We identified ineligible and unsupported questioned costs
of $507,804 and $204,988, respectively, resulting in total questioned costs of
$712,792. We also determined North Dakota’s risk of unallowable use of funds is
moderate.
Castro recommends Treasury OIG confirm the transactions noted as unsupported
or ineligible expenditures within the Contracts greater than or equal to $50,000,
Direct Payments greater than or equal to $50,000, Aggregate Reporting less than
$50,000, and Aggregate Payments to Individuals payment types are recouped or
replaced by other eligible expenditures, not previously charged to CRF, that were
incurred during the period of performance. Based on North Dakota management’s
responsiveness to Treasury OIG’s requests and their ability to provide sufficient
documentation, we recommend Treasury OIG determine the feasibility of
conducting an audit for the Contracts greater than or equal to $50,000, Direct
Payments greater than or equal to $50,000, Aggregate Reporting less than
$50,000, and Aggregate Payments to Individuals payment types.
At the time of the desk review fieldwork, Castro noted that North Dakota had
findings in their Single Audit reports for fiscal years 2021/2022 (combined report).
Castro recommends that Treasury OIG follow-up with Treasury’s Office of Capital
Access to ensure that management decision letters are issued on the CRF specific
9
A transfer to another government entity is a disbursement or payment to a government entity
that is legally distinct from the prime recipient.
10
Prime recipients were required to report CRF transactions greater than or equal to $50,000 in
detail in the GrantSolutions portal. Transactions less than $50,000 could be reported as an
aggregate lump-sum amount by type (contracts, grants, loans, direct payments, and transfers to
other government entities).
11
Obligations and expenditures for payments made to individuals, regardless of amount, were
required to be reported in the aggregate in the GrantSolutions portal to prevent inappropriate
disclosure of personally identifiable information.
findings identified by the auditor in these Single Audit reports, which we have
summarized below:
o North Dakota’s fiscal year 2020 Single Audit report was published on
March 17, 2021, and the auditor did not include any CRF related questioned
costs.
o North Dakota’s fiscal year 2021/2022 combined Single Audit report was
published on March 29, 2023, and the auditor determined unsupported
questioned costs specific to the CRF in the amount of $617,870.
We recommend Treasury OIG follow-up on any CRF specific questioned costs
reported in the fiscal year 2021/2022 combined Single Audit report.
Non-Statistical Transaction Selection Methodology
Treasury issued a $1,250,000,000 CRF payment to North Dakota. As of
September 30, 2023, North Dakota’s cumulative obligations and expenditures
were both $1,249,964,457. North Dakota returned a total of $35,543 in CRF
proceeds to Treasury. North Dakota’s cumulative obligations and expenditures by
payment type are summarized below.
Cumulative Cumulative
Payment Type Obligations Expenditures
Contracts >= $50,000 $ 137,037,545 $ 137,037,545
Grants >= $50,000 $ 197,463,865 $ 197,463,865
Loans >= $50,000 $ - $ -
Transfers >= $50,000 $ 124,046,303 $ 124,046,303
Direct Payments >= $50,000 $ 128,336,762 $ 128,336,762
Aggregate Reporting < $50,000 $ 148,703,397 $ 148,703,397
Aggregate Payments to
Individuals (in any amount) $ 514,376,585 $ 514,376,585
Totals $ 1,249,964,457 $ 1,249,964,457
Castro made a non-statistical selection of the Contracts greater than or equal
to $50,000, Grants greater than or equal to $50,000, Transfers greater than or
equal to $50,000, Direct Payments greater than or equal to $50,000, Aggregate
Reporting less than $50,000, and Aggregate Payments to Individuals payment
types. Selections were made using auditor judgment based on information and
risks identified in reviewing audit reports, the GrantSolutions portal reporting
anomalies12 identified by the Treasury OIG CRF monitoring team, and review of
12
Treasury OIG had a pre-defined list of risk indicators that were triggered based on data
submitted by prime recipients in the FPR submissions that met certain criteria. Castro reviewed
these results provided by Treasury OIG for the prime recipient.
North Dakota’s FPR submissions. North Dakota did not obligate or expend CRF
proceeds to the Loans greater than or equal to $50,000 payment type; therefore,
we did not make a selection of transactions from this payment type.
The number of transactions (27) we selected to test was based on North Dakota’s
total CRF award amount and our overall risk assessment of North Dakota. To
allocate the number of transactions (27) by payment type (Contracts greater than
or equal to $50,000, Grants greater than or equal to $50,000, Transfers greater
than or equal to $50,000, Direct Payments greater than or equal to $50,000,
Aggregate Reporting less than $50,000, and Aggregate Payments to Individuals),
we compared the payment type dollar amounts as a percentage of cumulative
expenditures as of September 30, 2023. The transactions selected for testing were
not selected statistically, and therefore results could not be extrapolated to the
total universe of transactions.
Background
The CARES Act appropriated $150 billion to establish the CRF. Under the CRF,
Treasury made payments for specified uses to States and certain local
governments; the District of Columbia and U.S. Territories, including the
Commonwealth of Puerto Rico, the U.S. Virgin Islands, Guam, American Samoa,
and the Commonwealth of the Northern Mariana Islands; and Tribal governments
(collectively referred to as “prime recipients”). Treasury issued a $1,250,000,000
CRF payment to North Dakota. The CARES Act stipulates that a prime recipient
may only use the funds to cover costs that—
(1) were necessary expenditures incurred due to the public health
emergency with respect to the coronavirus disease 2019 (COVID-19);
(2) were not accounted for in the budget most recently approved as of
March 27, 2020; and
(3) were incurred during the covered period between March 1, 2020 and
December 31, 2021. 13
13
P.L. 116-260 (December 27, 2020). The covered period end date of the CRF was extended through
December 31, 2021 by the Consolidated Appropriations Act, 2021. The covered period end date for
tribal entities was further extended to December 31, 2022 by the State, Local, Tribal, and Territorial
Fiscal Recovery, Infrastructure, and Disaster Relief Flexibility Act, Division LL of the Consolidated
Appropriations Act, 2023, P.L. 117-328, December 29, 2022, 136 Stat. 4459.
Section 15011 of the CARES Act required each covered recipient 14 to submit to
Treasury and the Pandemic Response Accountability Committee, no later than 10
days after the end of each calendar quarter, a report that contained (1) the total
amount of large, covered funds 15,16 received from Treasury; (2) the amount of
large, covered funds received that were expended or obligated for each project or
activity; (3) a detailed list of all projects or activities for which large, covered funds
were expended or obligated; and (4) detailed information on any level of sub-
contracts or sub-grants awarded by the covered recipient or its sub-recipients.
The CARES Act assigned Treasury OIG the responsibility for compliance
monitoring and oversight of the receipt, disbursement, and use of CRF proceeds.
Treasury OIG also has the authority to recoup funds in the event that it is
determined a recipient failed to comply with requirements of subsection 601(d) of
the Social Security Act, as amended, (42 U.S.C. 801(d)).
Desk Review Results
Financial Reporting Control Issues
Castro reconciled the expenditures identified within the GrantSolutions portal as
of September 30, 2023, to North Dakota’s general ledger (GL) detail, which
resulted in identification of reconciling errors within the Contracts greater than or
equal to $50,000, Grants greater than or equal to $50,000, Transfers greater than
or equal to $50,000, Direct Payments greater than or equal to $50,000, Aggregate
Reporting less than $50,000, and Aggregate Payment to Individuals payment
types, that Castro deemed to be reporting misclassifications that did not comply
with Treasury’s Guidance.
During Castro’s GL reconciliation procedures, we noted the GL details exceeded
the claimed amounts in the GrantSolutions portal by $938,184. We asked North
Dakota management to explain this difference, and they clarified that it was due to
inclusion of $944,835 in interest income within the CRF amounts claimed in the
GL. Additionally, North Dakota did not substantiate which payment types the
interest income was used to augment expenditures claimed within the GL detail
population amounts provided to us during our desk review. Based on review of
14
Section 15011 of P.L. 116-136, the CARES Act, defined a covered recipient as any entity that
received large, covered funds and included any State, the District of Columbia, and any territory or
possession of the United States.
15
Section 15010 of P.L. 116-136, the CARES Act, defined covered funds as any funds, including
loans, that were made available in any form to any non-Federal entity, not including an individual,
under Public Laws 116-123, 127, and 136, as well as any other law which primarily made
appropriations for Coronavirus response and related activities.
16
Section 15011 of P.L. 116-136 defined large, covered funds as covered funds that amounted to
more than $150,000.
the Treasury’s Guidance within OIG-20-028R FAQ# 50, 17 Castro determined that
the use of interest income towards CRF related expenses was allowable; however,
the interest and expenses should be separately tracked. As such, we excluded the
$944,835 of interest income from the GL expenditure population amount of
$1,250,902,641. Castro compared the expenses excluding the interest income
figures and determined that there was a variance of $6,651 between the amount
of $1,249,964,457 reported in the GrantSolutions portal and the amount of
$1,249,957,806 evidenced within the GL details. Refer to calculations in the table
below.
Cumulative Cumulative
Expenditures per Expenditures Per GL
Payment Type FPR Populations Difference
Contracts >= $50,000 $ 137,037,545 $ 137,185,197 $ (147,651)
Grants >= $50,000 $ 197,463,865 $ 196,866,956 $ 596,909
Loans >= $50,000 $ - $ - $ -
Transfers >= $50,000 $ 124,046,303 $ 123,845,007 $ 201,295
Direct Payments >=
$50,000 $ 128,336,762 $ 129,258,423 $ (921,661)
Aggregate Reporting <
$50,000 $ 148,703,397 $ 149,310,562 $ (607,165)
Aggregate Payments to
Individuals (in any
amount) $ 514,376,585 $ 514,436,496 $ (59,911)
Sub-Totals $ 1,249,964,457 $ 1,250,902,641 $ (938,184)
Less Interest Income (-) N/A $ 944,835 $ 944,835
Total Difference $ 1,249,964,457 $ 1,249,957,806 $ 6,651
We recommend that Treasury OIG requests that North Dakota management
conduct an assessment to remove the interest income from the payment types
provided in its GL detail reconciliation and to provide Treasury OIG with an
updated GL detail reconciliation. Based on the results of this analysis, we
recommend Treasury OIG obtain an updated GL detail to determine if it supports
the $6,651.
17
Per the Department of the Treasury Office of Inspector General Coronavirus Relief Fund
Frequently Asked Questions Related to Reporting and Recordkeeping OIG-20-028R; March 2, 2021,
FAQ #50: “Treasury’s FAQs state that prime recipients may deposit CRF payments into separate
interest-bearing accounts. How should interest earned and expended be reported? The prime
recipient is responsible for tracking interest earned and expended separately…if a recipient
separately invests CRF proceeds in an interest-bearing account, the prime recipient must use the
interest earned (only to cover expenditures incurred in accordance with section 601(d) of the Social
Security Act (42 U.S.C. 801(d)) and the Guidance on eligible expenses).”
Financial Progress Reports
We reviewed North Dakota’s quarterly FPRs through September 30, 2023, and
found that North Dakota timely filed quarterly FPRs in the GrantSolutions portal in
compliance with Treasury OIG reporting requirements for the periods ending
June 30, 2020 through September 30, 2023.
Summary of Testing Results
We found that the Grants greater than or equal to $50,000 and the Transfers
greater than or equal to $50,000 payment types complied with the CARES Act but
did not comply with Treasury’s Guidance. Additionally, we found that the
Contracts greater than or equal to $50,000, Direct Payments greater than or equal
to $50,000, Aggregate Reporting less than $50,000, and Aggregate Payments to
Individuals payment types did not comply with the CARES Act and Treasury’s
Guidance because we were unable to determine if all tested expenditures were
necessary due to the COVID-19 public health emergency, were not accounted for
in the budget most recently approved as of March 27, 2020, and were incurred
during the covered period. The transactions selected for testing were not selected
statistically, and therefore results could not be extrapolated to the total universe
of transactions.
Within the table below, we have included a summary of unsupported and
ineligible expenditures identified as questioned costs, which did not comply with
the CARES Act and Treasury’s Guidance. See the Desk Review Results section
below this table for a detailed discussion of questioned costs and other issues
identified throughout the course of our desk review.
Summary of Expenditures Testing and Recommended Results
As of September 30, 2023
Cumulative
Expenditure Cumulative Unsupported Ineligible Total
Population Expenditure Questioned Questioned Questioned
Payment Type Amount Tested Amount Costs Costs Costs
Contracts >=
$50,000 $ 137,037,545 $ 3,493,263 $ 191,804 $ - $ 191,804
Grants >= $50,000 $ 197,463,865 $ 11,277,109 $ - $ - $ -
Loans >= $50,000 $ - $ - $ - $ - $ -
Transfers >=
$50,000 $ 124,046,303 $ 8,003,025 $ - $ - $ -
Direct Payments
>= $50,000 $ 128,336,762 $ 10,305,425 $ - $ 507,804 $ 507,804
Aggregate
Reporting <
$50,000 $ 148,703,397 $ 557,208 $ 484 $ - $ 484
Aggregate
Payments to
Individuals (in any
amount) $ 514,376,585 $ 14,707,924 $ 12,700 $ - $ 12,700
Totals $ 1,249,964,457 $ 48,343,954 $ 204,988 $ 507,804 $ 712,792
Contracts Greater Than or Equal to $50,000
We determined North Dakota’s Contracts greater than or equal to $50,000 did not
comply with the CARES Act and Treasury’s Guidance. We tested three contracts,
totaling $3,493,263. The contracts tested included expenditures for the purchase
of information technology consulting services to address the COVID-19 pandemic;
tourism and marketing services; and a business interruption assistance grant
program. We identified exceptions related to one contract, which resulted in
unsupported questioned costs totaling $191,804, as detailed below.
Additionally, we identified one reporting misclassification that we determined did
not comply with Treasury’s Guidance related to Contracts greater than or equal to
$50,000 that we determined should have been reported as Grants greater than or
equal to $50,000 in the GrantSolutions portal, as detailed below.
Grant Program Related to Oil Well Drilling Exception
We tested five invoices totaling $883,044 that North Dakota claimed under a
$16,000,000 grant program supporting the employment of frac crews 18 to
complete drilled but uncompleted (“DUC”) oil wells. The grant program
documentation explained the purpose of the funding was to provide economic
support to assist with continued employment of frac crews and minimize further
impacts of increased unemployment rates as a result of the COVID-19 pandemic.
North Dakota approved the use of CRF proceeds to complete drilling on up to 80
wells by December 30, 2020, with a reimbursement of up to $200,000 in water
acquisition and disposal costs. We determined this was a reporting
misclassification that did not comply with Treasury’s Guidance, as this program
was reported by North Dakota as a Contract greater than or equal to $50,000 but
should have been reported as a Grant greater than or equal to $50,000 in the
GrantSolutions portal.
For one of five invoices tested totaling $191,804, we noted North Dakota failed to
provide sufficient expenditure supporting documentation for the water acquisition
and disposal services, such as official vendor invoices to substantiate the voucher
details and secondary payment details, related to this program, resulting in
unsupported questioned costs of $191,804.
Since Castro identified unsupported questioned costs within the amounts we
tested related to the DUC oil well grant program, we recommend Treasury OIG
determine the feasibility of performing additional follow-up with North Dakota to
determine if there were other instances of unsupported balances within the DUC
oil well grant program.
Grants Greater Than or Equal to $50,000
We determined North Dakota’s Grants greater than or equal to $50,000 complied
with the CARES Act, but not with Treasury’s Guidance. We tested four grants,
totaling $11,277,109 and identified no questioned costs. The grants tested
included expenditures related to reimbursements for the public-school education
system and students; North Dakota’s Department of Commerce economic
resiliency grant for businesses to reduce the spread of COVID-19, such as
improvements related to social distancing; a meat processing plant cost-share
program, and public health expenses for city facilities.
18
A frac crew is a specialized team responsible for hydraulic fracturing in oil and gas
extraction. They design plans, operate equipment, and maintain machinery.
We tested one transaction totaling $172,432 that North Dakota claimed under the
Department of Commerce’s Economic Resiliency Grant Program, which required
small businesses to make investments in a process that reduced repetitive touch
and created distance between customers and employees, and supported
purchases of personal protective equipment. We noted North Dakota overstated
the amounts claimed in the GrantSolutions portal by $100,000 under the Grants
greater than or equal to $50,000 payment type as of September 30, 2023. Castro
reviewed North Dakota's supporting documentation and noted that North Dakota
indicated the payment for $100,000 issued on September 23, 2020, was voided
and confirmed the overstatement was not corrected in the GrantSolutions portal
as of September 30, 2023. Per Treasury OIG’s Reporting and Recordkeeping
Frequently Asked Questions guidance, prime recipients should make appropriate
modifications to reported information in the GrantSolutions portal. After their final
GrantSolutions portal submission, which was deemed non-compliant with
Treasury’s Guidance, North Dakota returned the $100,000 voided payment to
Treasury in February 2024 and Treasury OIG confirmed receipt of the return from
North Dakota. No further procedures were deemed necessary, and we questioned
no costs related to this transaction for our desk review.
Transfers to Other Government Entities Greater Than or Equal to $50,000
We determined North Dakota’s Transfers to Other Government Entities greater
than or equal to $50,000 complied with the CARES Act but not with Treasury’s
Guidance. We tested three transfers totaling $8,003,025 and identified no
exceptions. The transfers tested included expenditures for information technology
services to support teleworking during the pandemic, and payroll costs for
licensed law enforcement officials.
Additionally, Castro identified a reporting misclassification that did not comply
with Treasury’s Guidance, as North Dakota reported certain transactions in the
Aggregate Transfer less than $50,000 payment type when the transactions should
have been reported under Transfers greater than or equal to $50,000. See
Aggregate Reporting less than $50,000 payment type section below for additional
details.
Direct Payments Greater Than or Equal to $50,000
We determined North Dakota’s Direct Payments greater than or equal to $50,000
did not comply with the CARES Act and Treasury’s Guidance. We tested three
direct payments totaling $10,305,425. The direct payments tested included
expenditures for the purchase of cybersecurity services, childcare provider
payments to defray operating costs, remote equipment for legislative assembly
voting, and a connection fiber ring project to promote remote learning. We
identified one exception, resulting in ineligible questioned costs of $507,804, as
detailed below.
Direct Payments Exception - Cybersecurity Services Ineligible Questioned Costs
We tested one transaction totaling $9,511,772 claimed for a contract with a vendor
to provide cybersecurity services, including professional services to assist with
setting up cybersecurity tools, training North Dakota’s Information Technology
Department staff, and monitoring a larger virtual private network solution due to
increased demand for teleworking during the pandemic. Castro determined that
one of North Dakota’s sub-recipients purchased 3 and 5-year prepaid
subscriptions during the CRF covered period, which required obligations to be
made by December 31, 2021. Castro considered North Dakota to have obligated
the funds for the license contract within the covered period.
Castro noted that the subscriptions would be active through 2023 and 2025, which
a portion was outside of Treasury’s final period for North Dakota to expend
obligated funds from the CRF, September 30, 2022. 19 For each subscription, we
determined the amount of time that would fall after September 30, 2022, and
utilized this to calculate the dollar amount associated with the portion of these
prepaid subscriptions that was unused and therefore not fully expended prior to
September 30, 2022.
Castro determined the ineligible portion of the total prepaid expenditures claimed
by North Dakota was $507,804, which consisted of questioned costs of $366,882
and $140,922 for the 3 and 5-year subscription plan prepayments respectively.
Castro considers these ineligible questioned costs of $507,804 since the amounts
associated with the subscription time were outside of Treasury’s period to expend
funds received from CRF.
19
Coronavirus Relief Fund Guidance as published in the Federal Register (December 14,
2021) CRF-Guidance_Revision-Regarding-Cost-Incurred.pdf (Treasury.gov) states: “Costs
incurred during the period that begins on March 1, 2020, and ends on December 31, 2021.
The CARES Act provides that payments from the Fund may only be used to cover costs that
were incurred during the period that begins on March 1, 2020, and ends on December 31,
2021 (the “covered period”). A cost associated with a necessary expenditure incurred due
to the public health emergency is considered to have been incurred by December 31, 2021,
if the recipient has incurred an obligation with respect to such cost by December 31, 2021.
Treasury defines obligation for this purpose as an order placed for property and services
and entry into contracts, subawards, and similar transactions that require payment.
Recipients are required to expend their funds received from the CRF to cover these
obligations by September 30, 2022.”
Since Castro identified ineligible questioned costs related to subscriptions in the
GrantSolutions portal, we recommend Treasury OIG follow-up with North Dakota
management and request North Dakota to perform an analysis over all of their
GrantSolutions portal reported balances to determine if there were other
instances of subscription costs included in the CRF reported expenditures and
review those expenditures to determine if there were other instances of
subscription costs that extended past September 30, 2022.
Aggregate Reporting Less Than $50,000
We determined North Dakota’s Aggregate Reporting less than $50,000 did not
comply with the CARES Act and Treasury’s Guidance. We tested four transactions
totaling $557,208. The transactions tested included payroll costs for public health
and safety employees, 20 hardware equipment for remote work state employees,
heating, ventilation, and air conditioning air purification systems for nursing home
facilities, and the purchase of personal protective equipment. We identified one
exception, resulting in unsupported questioned costs of $484, as detailed below.
Additionally, Castro identified a reporting misclassification that did not comply
with Treasury’s Guidance, as North Dakota reported certain transactions in the
Aggregate Payments less than $50,000 payment type when the transactions
should have been reported under Transfers greater than or equal to $50,000.
Aggregate Reporting Exception - Public Health and Safety Payroll
We tested five invoices totaling $121,435 that North Dakota claimed under the
North Dakota Office of Management and Budget’s $58.9 million program to
allocate funding to cities and counties based on salary and benefit expenses for
licensed law enforcement officers. For one of the invoices tested to reimburse
payroll costs of McIntosh County law enforcement officials, we noted North
Dakota management provided insufficient supporting documentation to
recalculate the payroll costs issued to the public health and safety personnel.
Further, Castro identified a reporting misclassification that did not comply with
Treasury’s Guidance, as North Dakota reported certain transactions in the
20
Treasury’s Federal Register guidance provided the following examples of public health
and safety employees: “police officers (including state police officers), sheriffs and deputy
sheriffs, firefighters, emergency medical responders, correctional and detention officers,
and those who directly support such employees such as dispatchers and supervisory
personnel… employees involved in providing medical and other health services to
patients and supervisory personnel, including medical staff assigned to schools, prisons,
and other such institutions, and other support services essential for patient care (e.g.,
laboratory technicians) as well as employees of public health departments directly
engaged in matters related to public health and related supervisory personnel.”
Aggregate Payments less than $50,000 payment type when the transactions
should have been reported under Transfers greater than or equal to $50,000.
For one invoice totaling $14,646, we noted Treasury’s Federal Register allowed an
administrative accommodation 21 to public health and safety personnel; however,
the pay periods used to reimburse the McIntosh County law enforcement officials
were from an incorrect fiscal year. North Dakota approved the McIntosh County
reimbursement on January 5, 2021, however, the paystub used to support the
reimbursement request indicated payroll costs were earned between
December 15, 2021, through December 30, 2021. We requested that North Dakota
management provide additional supporting documentation from the correct pay
periods, December 15, 2020, and December 31, 2020. Upon inspection of the
payroll support, we identified eligible expenditures totaling $14,162 which
generated a difference of $484 in comparison to the reimbursement request
totaling $14,646. We determined the payroll discrepancy between fiscal years
resulted in unsupported questioned costs of $484.
Aggregate Payments to Individuals
CRF payments made to individuals, regardless of amount, were required to be
reported in the aggregate in the GrantSolutions portal to prevent inappropriate
disclosure of personally identifiable information. Castro notes that Aggregate
Payments to Individuals consisted of the following broad types of potential costs
which we have defined from Treasury’s guidance as published in the Federal
Register, 22 where applicable. Prime recipients may or may not have claimed all of
these types of expenditures.
21
Treasury’s Federal Register guidance indicates that administrative accommodation
means that “In recognition of the particular importance of public health and public safety
workers to State, local, and tribal government responses to the public health emergency,
Treasury has provided, as an administrative accommodation, that a State, local, or tribal
government may presume that public health and public safety employees meet the
substantially dedicated test…This means that, if this presumption applies, work
performed by such employees is considered to be a substantially different use than
accounted for in the most recently approved budget as of March 27, 2020. All costs of
such employees may be covered using payments from the Fund for services provided
during the period that begins on March 1, 2020, and ends on December 31, 2021.”
22
Coronavirus Relief Fund Guidance as published in the Federal Register (January 15,
2021) https://home.treasury.gov/system/files/136/CRF-Guidance-Federal-Register_2021-
00827.pdf
Public Safety/Health Payroll – consisted of payroll costs for public
health and safety department personnel.
Substantially Dedicated Payroll 23 – consisted of payroll costs for
non-public health and safety personnel who were substantially
dedicated to mitigating or responding to the COVID-19 public health
emergency.
Non-Substantially Dedicated Payroll 24 – consisted of payroll costs
for personnel who performed COVID-19 related tasks on a part-time
basis.
Non-Payroll Expenditures – consisted of financial assistance
payments to citizens due to hardship or loss of income,
unemployment claims, and other non-payroll related expenditures
made to individuals.
23
Substantially dedicated payroll costs means that personnel must have dedicated over
50 percent of their time to responding to or mitigating COVID-19. Treasury’s Federal
Register guidance indicates that: “The full amount of payroll and benefits expenses of
substantially dedicated employees may be covered using payments from the Fund.
Treasury has not developed a precise definition of what "substantially dedicated" means
given that there is not a precise way to define this term across different employment
types. The relevant unit of government should maintain documentation of the
"substantially dedicated" conclusion with respect to its employees.”
24
Payroll costs that are not substantially dedicated means payroll costs that are not public
health and safety, and which are not substantially dedicated to performing COVID-19
related tasks. Federal Register guidance defines more stringent tracking requirements for
these types of payroll costs. Specifically, the Federal Register states that agencies must:
“track time spent by employees related to COVID-19 and apply Fund payments on that
basis but would need to do so consistently within the relevant agency or department. This
means, for example, that a government could cover payroll expenses allocated on an
hourly basis to employees' time dedicated to mitigating or responding to the COVID-19
public health emergency.”
The North Dakota Aggregate Payments to Individuals balance consisted of payroll
and other transactions from the following categories of claimed costs.
Total Expenses
Aggregate Payments to Individuals Category Types
Claimed
Public Health and Safety Payroll $ 33,543,625
Substantially Dedicated Payroll $ 6,219,710
Non-Substantially Dedicated Payroll $ 79,900,050
Non-Payroll Expenditures 25 $ 394,773,111
Totals 26 $ 514,436,496
Castro noted that public health and safety payroll transactions were subject to
Treasury’s administrative accommodation, and therefore, were subject to less
detailed documentation requirements. Castro tested public health and safety
payroll transactions by reviewing itemized payroll distribution reports to support
these balances. Substantially dedicated and non-substantially dedicated payroll
balances were not subject to this administrative accommodation, and therefore,
Castro tested these transactions by reviewing the prime recipient’s substantially
dedicated conclusion with respect to its employees and payroll distribution files,
and by performing tests over specific employee timesheet submissions.
Transactions classified as non-payroll expenditures vary depending on the type of
expenses that were reimbursed with CRF, and therefore, Castro performed
analytical procedures and testing on transactions by reviewing the applicable
underlying guidelines and details provided as support by North Dakota.
We determined North Dakota’s Aggregate Payments to Individuals did not comply
with the CARES Act and Treasury’s Guidance. We tested 10 transactions totaling
$14,707,924. We tested transactions related to unemployment insurance
expenditures, payroll costs for executive management, payroll for public health
and safety employees, substantially and non-substantially dedicated payroll costs,
and additional and part-time staff for remote enrollment. We identified one
exception, resulting in unsupported questioned costs totaling $12,700, as detailed
below.
25
As demonstrated in the table above, North Dakota expended approximately 77 percent of their
Aggregate Payments to Individuals CRF proceeds within Non-Payroll Expenditures. Of the
approximately $394.8 million claimed, approximately $355.6 million was used for unemployment
related expenditures. Refer to the Unemployment Replenishment Analysis section below.
26
The Aggregate Payments to Individuals Analysis above prepared by North Dakota did
not reconcile to the amounts claimed per the GrantSolutions portal as of
September 30, 2023, by $59,911, due to interest earned included in the underlying details
to generate the report. We did not identify any questioned costs related to the financial
reporting control issues. Refer to Financial Reporting Control Issues section above for
more detail.
Substantially Dedicated Payroll Exception
We tested one transaction totaling $12,700 claimed for payroll related costs
incurred by the North Dakota Chief Operating Officer in connection with the state
planning of the COVID-19 pandemic response. North Dakota considered the Chief
Operating Officer a substantially dedicated employee for dedicating 100 percent of
their efforts on the COVID-19 response. North Dakota was unable to provide
adequate supporting documentation to evidence the payroll related costs were
eligible and allowable in conjunction with the CARES Act and Treasury’s
Guidance, resulting in unsupported questioned costs of $12,700.
North Dakota management attested that the individual was part of executive
management; therefore, North Dakota did not provide documentation of the
substantially dedicated conclusion with respect to this employee to justify the
eligible and allowable use of CRF proceeds, or any evidence of timesheets, or the
number of hours charged and/or allocated to CRF related tasks. We asked North
Dakota to provide any support indicating the employee dedicated 100 percent of
their efforts to the COVID-19 response. North Dakota stated that the employee’s
time was 100 percent devoted to the Public Health Education, which included
coordinating information that was provided to the public, Health Department, and
other state agencies. Based on our assessment, we determined North Dakota did
not provide sufficient documentation of the substantially dedicated conclusion
with respect to this employee to justify the eligible and allowable use of CRF
proceeds. As a result, Castro questioned $12,700 as unsupported.
Unemployment Insurance Replenishment Analysis
The non-payroll transactions reviewed consisted of $126,179,658 in payments
from May 2020 through June 2020 to replenish North Dakota’s Unemployment
Insurance Trust Fund. In conjunction with the transactions tested, North Dakota
provided the North Dakota Job Service Department’s unemployment claims
analysis supporting how the state determined that the change in this balance
(unemployment claims paid) occurred due to the COVID-19 pandemic and not due
to unemployment claims that would have been paid regardless of the pandemic.
North Dakota experienced a significant decline in the Unemployment Insurance
Trust Fund balance from March 2020 through May 2020 of approximately
$89 million. Upon inspection of North Dakota’s unemployment claims analysis,
we noted actual unemployment benefits expenditures were $383,378,368. The
increase of unemployment benefits claimed directly impacted North Dakota’s
Unemployment Insurance Trust Fund balance which increased the risk of potential
insolvency. North Dakota's unemployment claims analysis summarized the
inflows and outflows of the Unemployment Insurance Trust Fund Balance during
the covered period. Based on our observation, we determined North Dakota had
more eligible expenditures than reimbursed with CRF in the amount of
$27,724,725. We recalculated this amount from obtaining the CRF proceeds
reported or replenished into the fund in the amount of $355,653,643 and
subtracted this amount from the benefit claims that were attributable to COVID-19.
Castro concluded that North Dakota’s CRF replenishment payment consisted of an
Unemployment Insurance Trust Fund replenishment payment and not an
augmentation to the Unemployment Insurance Trust Fund. Additionally, Castro
determined these payments were necessary due to the COVID-19 pandemic and
did not represent unemployment claims that would have been paid regardless of
the pandemic.
Conclusion
We determined the expenditures related to the Grants greater than or equal
to $50,000 and the Transfers greater than or equal to $50,000 payment types
complied with the CARES Act but did not comply with Treasury’s Guidance.
Additionally, we found that the Contracts greater than or equal to $50,000, Direct
Payments greater than or equal to $50,000, Aggregate Reporting less than
$50,000, and Aggregate Payments to Individuals payment types did not comply
with the CARES Act and Treasury’s Guidance, resulting in unsupported and
ineligible questioned costs of $204,988 and $507,804, respectively, with total
questioned costs of $712,792.
Castro also identified reporting error misclassifications within the Contracts
greater than or equal to $50,000, Grants greater than or equal to $50,000,
Transfers greater than or equal to $50,000, Direct Payments greater than or equal
to $50,000, Aggregate Reporting less than $50,000, and Aggregate Payment to
Individuals payment types that we considered non-compliant with Treasury’s
Guidance.
Additionally, North Dakota’s risk of unallowable use of funds is moderate. As a
result of this desk review, we recommend Treasury OIG:
Confirm the transactions noted as unsupported or ineligible expenditures
within the Contracts greater than or equal to $50,000, Direct Payments
greater than or equal to $50,000, Aggregate Reporting less than $50,000,
and Aggregate Payments to Individuals payment types are recouped or
replaced by other eligible expenditures, not previously charged to CRF,
that were incurred during the period of performance. Based on North
Dakota management’s responsiveness to Treasury OIG’s requests and its
ability to provide sufficient documentation, we recommend Treasury OIG
determine the feasibility of conducting an audit for the Contracts greater
than or equal to $50,000, Direct Payments greater than or equal to
$50,000, Aggregate Reporting less than $50,000, and Aggregate
Payments to Individuals payment types.
At the time of desk review fieldwork, Castro noted that North Dakota had
findings in their Single Audit Reports for fiscal years 2021/2022
(combined report). Castro recommends that Treasury OIG follow-up with
Treasury’s Office of Capital Access to ensure that management decision
letters are issued on the findings identified by the auditor in the Single
Audit Report, which we have summarized below:
o North Dakota’s fiscal year 2020 Single Audit Report was published
on March 17, 2021, and the auditor did not identify any
unsupported questioned costs specific to the CRF.
o North Dakota’s fiscal years 2021-2022 Single Audit Report was
published on March 29, 2023, and the auditor determined
unsupported questioned costs specific to the CRF totaling
$617,870.
We recommend Treasury OIG follow-up on any CRF specific questioned
costs reported in the fiscal year 2021-2022 Single Audit report.
Castro also identified other matters throughout the course of our desk review,
which warrant recommendations to Treasury OIG for additional action. Castro
made recommendations to Treasury OIG related to the following issues:
Since Castro identified unsupported questioned costs within the amounts
we tested related to the DUC oil well grant program, we recommend
Treasury OIG determine the feasibility of performing additional follow-up
with North Dakota to determine if there were other instances of
unsupported balances within the DUC oil well grant program.
Follow-up with North Dakota and request North Dakota perform an
analysis over all of their GrantSolutions portal reported balances to
determine if there were other instances of subscription costs included in
the CRF reported expenditures and review those expenditures to
determine if there were other instances of subscription costs that
extended past September 30, 2022.
North Dakota provided underlying details that separately tracked interest
bearing income accounts of $938,184 within the accounting system;
however, North Dakota did not substantiate which payment types the
interest income were claimed in within the GL detail population amounts
provided to us during our desk review. We recommend Treasury OIG
request that North Dakota management conduct an assessment to
remove the interest income from the payment types provided in its GL
detail reconciliation and to provide Treasury OIG with an updated GL
detail reconciliation. Based on the results of this analysis, we recommend
Treasury OIG obtain an updated GL detail to determine if it supports the
$6,651.
*****
All work completed with this letter complies with the Council of the Inspectors
General on Integrity and Efficiency’s Quality Standards for Federal Offices of
Inspectors General, which require that the work adheres to the professional
standards of independence, due professional care, and quality assurance to
ensure the accuracy of the information presented. 27 We appreciate the courtesies
and cooperation provided to our staff during the desk review.
Sincerely,
Wayne Ference
Partner, Castro & Company, LLC
27
https://www.ignet.gov/sites/default/files/files/Silver%20Book%20Revision%20-%208-20-12r.pdf
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