2021‐004 – Deficiency in Cash Management Controls over Compliance – Significant Deficiency
Federal Program Information
Funding Agency: U.S. Department of Commerce, Minority
Business Development Agency
Federal Award Agreement Number: Not Applicable
Award Year: 2021
Title: MBDA Business Center
CFDA Number: 11.805
Pass‐through Agency: Not Applicable, Direct Program
Pass‐through Identification Number: Not Applicable, Direct Program
Condition ‐ The Entity does not have policies in procedures to ensure bank reconciliations are being
performed on a timely basis and reviewed and approved by someone other than the person
preparing.
Criteria ‐ 2 CFR section 200.303 – Internal Controls of the Uniform Guidance states that the nonfederal
entity must: (a) Establish and maintain effective internal controls over Federal award that
provides reasonable assurance that the non‐Federal entity is managing the Federal award in
compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
These internal controls should be in compliance with guidance in “Standards for Internal Control in
the Federal Government” issued by the Comptroller General of the United States or the “Internal
Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the
Treadway Commission (COSO).
Questioned Costs ‐ Not applicable.
Effect ‐ Bank reconciliations not performed on a timely manner may not detect misstatements or
errors.
Cause ‐ The Entity does not have proper controls in place to verify federal funds are received for the
amount requested on a timely basis or retain detailed support reconciliations are being performed.
2021‐005 – Deficiency in Special Tests and Provision Controls over Compliance with Training –
Significant Deficiency
Federal Program Information
Funding Agency: U.S. Department of Commerce, Minority
Business Development Agency
Federal Award Agreement Number: Not Applicable
Award Year: 2021
Title: MBDA Business Center
CFDA Number: 11.805
Pass‐through Agency: Not Applicable, Direct Program
Pass‐through Identification Number: Not Applicable, Direct Program
Condition ‐ The Entity was unable to provide support to test controls over compliance over training.
Criteria – 2 CFR section 200.303 – Internal Controls of the Uniform Guidance states that the nonfederal
entity must: (a) Establish and maintain effective internal controls over Federal award that
provides reasonable assurance that the non‐Federal entity is managing the Federal award in
compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
These internal controls should be in compliance with guidance in “Standards for Internal Control in
the Federal Government” issued by the Comptroller General of the United States or the “Internal
Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the
Treadway Commission (COSO).
Questioned Costs ‐ Not applicable.
Effect ‐ The Entity may unintentionally miss a required training which could lead to repayment of
funds.
Cause ‐ The Entity is not following its policy to ensure all mandatory training is completed as needed.
2021‐006 – Deficiencies in Activities Allowed, Allowable Costs, and Period of Performance Controls
over Compliance with Payroll – Significant Deficiency
Federal Program Information
Funding Agency: U.S. Department of Commerce, Minority
Business Development Agency
Federal Award Agreement Number: Not Applicable
Award Year: 2021
Title: MBDA Business Center
CFDA Number: 11.805
Pass‐through Agency: Not Applicable, Direct Program
Pass‐through Identification Number: Not Applicable, Direct Program
Condition ‐ During our review of payroll related transactions, the following were noted
For 5 of the 40 payroll transactions tested, the employee did not have an approved timesheet
or time and effort available for the pay period.
For 3 of the 40 payroll transactions tested, no timesheet or other record of hours worked was
available to support hours paid for the pay period.
For 1 of the 40 payroll transactions tested, employee was not paid for all hours worked on
timesheet.
Criteria – 2 CFR section 200.303 – Internal Controls of the Uniform Guidance states that the nonfederal
entity must: (a) Establish and maintain effective internal controls over Federal award that
provides reasonable assurance that the non‐Federal entity is managing the Federal award in
compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
These internal controls should be in compliance with guidance in “Standards for Internal Control in
the Federal Government” issued by the Comptroller General of the United States or the “Internal
Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the
Treadway Commission (COSO).
Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal
awards for salaries and wages must be based on records that accurately reflect the work performed.
Questioned Costs –$1,010
Effect ‐ The Entity may unintentionally expense employee’s salary out of the federal grant that does
not qualify or under/over compensate what is applicable for the work performed by that employee.
This could lead to questioned costs and repayment of funds to the Grantor agency. Cause ‐ The Entity does not have proper controls in place to verify that documentation was
maintained to indicate the employees’ time paid under the federal grant. Controls were put in place
during the year but were not consistently followed.
2021‐007 – Deficiency in Reporting Controls over Compliance with Financial Reporting – Significant
Deficiency
Federal Program Information
Funding Agency: U.S. Department of Commerce, Minority
Business Development Agency
Federal Award Agreement Number: Not Applicable
Award Year: 2021
Title: MBDA Business Center
CFDA Number: 11.805
Pass‐through Agency: Not Applicable, Direct Program
Pass‐through Identification Number: Not Applicable, Direct Program
Condition ‐ The Entity was unable to provide the annual SF‐424A or provide support it was submitted
on a timely basis. All other reporting under the program was submitted timely and accurately.
Criteria – 2 CFR section 200.303 – Internal Controls of the Uniform Guidance states that the nonfederal
entity must: (a) Establish and maintain effective internal controls over Federal award that
provides reasonable assurance that the non‐Federal entity is managing the Federal award in
compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal
controls should be in compliance with guidance in “Standards for Internal Control in the Federal
Government” issued by the Comptroller General of the United States or the “Internal Control
Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway
Commission (COSO).
Questioned Costs ‐ Not applicable.
Effect ‐ Not submitting an accurate annual report due on a timely basis could result in disallowed
costs.
Cause ‐ The Entity did not have sufficient controls in place to ensure all reporting is submitted to the
grantor agency accurately and on a timely basis, and to retain documentation of the reporting.
2021‐004 – Deficiency in Cash Management Controls over Compliance – Significant Deficiency
Federal Program Information
Funding Agency: U.S. Department of Commerce, Minority
Business Development Agency
Federal Award Agreement Number: Not Applicable
Award Year: 2021
Title: MBDA Business Center
CFDA Number: 11.805
Pass‐through Agency: Not Applicable, Direct Program
Pass‐through Identification Number: Not Applicable, Direct Program
Condition ‐ The Entity does not have policies in procedures to ensure bank reconciliations are being
performed on a timely basis and reviewed and approved by someone other than the person
preparing.
Criteria ‐ 2 CFR section 200.303 – Internal Controls of the Uniform Guidance states that the nonfederal
entity must: (a) Establish and maintain effective internal controls over Federal award that
provides reasonable assurance that the non‐Federal entity is managing the Federal award in
compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
These internal controls should be in compliance with guidance in “Standards for Internal Control in
the Federal Government” issued by the Comptroller General of the United States or the “Internal
Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the
Treadway Commission (COSO).
Questioned Costs ‐ Not applicable.
Effect ‐ Bank reconciliations not performed on a timely manner may not detect misstatements or
errors.
Cause ‐ The Entity does not have proper controls in place to verify federal funds are received for the
amount requested on a timely basis or retain detailed support reconciliations are being performed.
2021‐005 – Deficiency in Special Tests and Provision Controls over Compliance with Training –
Significant Deficiency
Federal Program Information
Funding Agency: U.S. Department of Commerce, Minority
Business Development Agency
Federal Award Agreement Number: Not Applicable
Award Year: 2021
Title: MBDA Business Center
CFDA Number: 11.805
Pass‐through Agency: Not Applicable, Direct Program
Pass‐through Identification Number: Not Applicable, Direct Program
Condition ‐ The Entity was unable to provide support to test controls over compliance over training.
Criteria – 2 CFR section 200.303 – Internal Controls of the Uniform Guidance states that the nonfederal
entity must: (a) Establish and maintain effective internal controls over Federal award that
provides reasonable assurance that the non‐Federal entity is managing the Federal award in
compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
These internal controls should be in compliance with guidance in “Standards for Internal Control in
the Federal Government” issued by the Comptroller General of the United States or the “Internal
Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the
Treadway Commission (COSO).
Questioned Costs ‐ Not applicable.
Effect ‐ The Entity may unintentionally miss a required training which could lead to repayment of
funds.
Cause ‐ The Entity is not following its policy to ensure all mandatory training is completed as needed.
2021‐006 – Deficiencies in Activities Allowed, Allowable Costs, and Period of Performance Controls
over Compliance with Payroll – Significant Deficiency
Federal Program Information
Funding Agency: U.S. Department of Commerce, Minority
Business Development Agency
Federal Award Agreement Number: Not Applicable
Award Year: 2021
Title: MBDA Business Center
CFDA Number: 11.805
Pass‐through Agency: Not Applicable, Direct Program
Pass‐through Identification Number: Not Applicable, Direct Program
Condition ‐ During our review of payroll related transactions, the following were noted
For 5 of the 40 payroll transactions tested, the employee did not have an approved timesheet
or time and effort available for the pay period.
For 3 of the 40 payroll transactions tested, no timesheet or other record of hours worked was
available to support hours paid for the pay period.
For 1 of the 40 payroll transactions tested, employee was not paid for all hours worked on
timesheet.
Criteria – 2 CFR section 200.303 – Internal Controls of the Uniform Guidance states that the nonfederal
entity must: (a) Establish and maintain effective internal controls over Federal award that
provides reasonable assurance that the non‐Federal entity is managing the Federal award in
compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
These internal controls should be in compliance with guidance in “Standards for Internal Control in
the Federal Government” issued by the Comptroller General of the United States or the “Internal
Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the
Treadway Commission (COSO).
Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal
awards for salaries and wages must be based on records that accurately reflect the work performed.
Questioned Costs –$1,010
Effect ‐ The Entity may unintentionally expense employee’s salary out of the federal grant that does
not qualify or under/over compensate what is applicable for the work performed by that employee.
This could lead to questioned costs and repayment of funds to the Grantor agency. Cause ‐ The Entity does not have proper controls in place to verify that documentation was
maintained to indicate the employees’ time paid under the federal grant. Controls were put in place
during the year but were not consistently followed.
2021‐007 – Deficiency in Reporting Controls over Compliance with Financial Reporting – Significant
Deficiency
Federal Program Information
Funding Agency: U.S. Department of Commerce, Minority
Business Development Agency
Federal Award Agreement Number: Not Applicable
Award Year: 2021
Title: MBDA Business Center
CFDA Number: 11.805
Pass‐through Agency: Not Applicable, Direct Program
Pass‐through Identification Number: Not Applicable, Direct Program
Condition ‐ The Entity was unable to provide the annual SF‐424A or provide support it was submitted
on a timely basis. All other reporting under the program was submitted timely and accurately.
Criteria – 2 CFR section 200.303 – Internal Controls of the Uniform Guidance states that the nonfederal
entity must: (a) Establish and maintain effective internal controls over Federal award that
provides reasonable assurance that the non‐Federal entity is managing the Federal award in
compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal
controls should be in compliance with guidance in “Standards for Internal Control in the Federal
Government” issued by the Comptroller General of the United States or the “Internal Control
Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway
Commission (COSO).
Questioned Costs ‐ Not applicable.
Effect ‐ Not submitting an accurate annual report due on a timely basis could result in disallowed
costs.
Cause ‐ The Entity did not have sufficient controls in place to ensure all reporting is submitted to the
grantor agency accurately and on a timely basis, and to retain documentation of the reporting.
2021‐004 – Deficiency in Cash Management Controls over Compliance – Significant Deficiency
Federal Program Information
Funding Agency: U.S. Department of Commerce, Minority
Business Development Agency
Federal Award Agreement Number: Not Applicable
Award Year: 2021
Title: MBDA Business Center
CFDA Number: 11.805
Pass‐through Agency: Not Applicable, Direct Program
Pass‐through Identification Number: Not Applicable, Direct Program
Condition ‐ The Entity does not have policies in procedures to ensure bank reconciliations are being
performed on a timely basis and reviewed and approved by someone other than the person
preparing.
Criteria ‐ 2 CFR section 200.303 – Internal Controls of the Uniform Guidance states that the nonfederal
entity must: (a) Establish and maintain effective internal controls over Federal award that
provides reasonable assurance that the non‐Federal entity is managing the Federal award in
compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
These internal controls should be in compliance with guidance in “Standards for Internal Control in
the Federal Government” issued by the Comptroller General of the United States or the “Internal
Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the
Treadway Commission (COSO).
Questioned Costs ‐ Not applicable.
Effect ‐ Bank reconciliations not performed on a timely manner may not detect misstatements or
errors.
Cause ‐ The Entity does not have proper controls in place to verify federal funds are received for the
amount requested on a timely basis or retain detailed support reconciliations are being performed.
2021‐005 – Deficiency in Special Tests and Provision Controls over Compliance with Training –
Significant Deficiency
Federal Program Information
Funding Agency: U.S. Department of Commerce, Minority
Business Development Agency
Federal Award Agreement Number: Not Applicable
Award Year: 2021
Title: MBDA Business Center
CFDA Number: 11.805
Pass‐through Agency: Not Applicable, Direct Program
Pass‐through Identification Number: Not Applicable, Direct Program
Condition ‐ The Entity was unable to provide support to test controls over compliance over training.
Criteria – 2 CFR section 200.303 – Internal Controls of the Uniform Guidance states that the nonfederal
entity must: (a) Establish and maintain effective internal controls over Federal award that
provides reasonable assurance that the non‐Federal entity is managing the Federal award in
compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
These internal controls should be in compliance with guidance in “Standards for Internal Control in
the Federal Government” issued by the Comptroller General of the United States or the “Internal
Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the
Treadway Commission (COSO).
Questioned Costs ‐ Not applicable.
Effect ‐ The Entity may unintentionally miss a required training which could lead to repayment of
funds.
Cause ‐ The Entity is not following its policy to ensure all mandatory training is completed as needed.
2021‐006 – Deficiencies in Activities Allowed, Allowable Costs, and Period of Performance Controls
over Compliance with Payroll – Significant Deficiency
Federal Program Information
Funding Agency: U.S. Department of Commerce, Minority
Business Development Agency
Federal Award Agreement Number: Not Applicable
Award Year: 2021
Title: MBDA Business Center
CFDA Number: 11.805
Pass‐through Agency: Not Applicable, Direct Program
Pass‐through Identification Number: Not Applicable, Direct Program
Condition ‐ During our review of payroll related transactions, the following were noted
For 5 of the 40 payroll transactions tested, the employee did not have an approved timesheet
or time and effort available for the pay period.
For 3 of the 40 payroll transactions tested, no timesheet or other record of hours worked was
available to support hours paid for the pay period.
For 1 of the 40 payroll transactions tested, employee was not paid for all hours worked on
timesheet.
Criteria – 2 CFR section 200.303 – Internal Controls of the Uniform Guidance states that the nonfederal
entity must: (a) Establish and maintain effective internal controls over Federal award that
provides reasonable assurance that the non‐Federal entity is managing the Federal award in
compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
These internal controls should be in compliance with guidance in “Standards for Internal Control in
the Federal Government” issued by the Comptroller General of the United States or the “Internal
Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the
Treadway Commission (COSO).
Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal
awards for salaries and wages must be based on records that accurately reflect the work performed.
Questioned Costs –$1,010
Effect ‐ The Entity may unintentionally expense employee’s salary out of the federal grant that does
not qualify or under/over compensate what is applicable for the work performed by that employee.
This could lead to questioned costs and repayment of funds to the Grantor agency. Cause ‐ The Entity does not have proper controls in place to verify that documentation was
maintained to indicate the employees’ time paid under the federal grant. Controls were put in place
during the year but were not consistently followed.
2021‐007 – Deficiency in Reporting Controls over Compliance with Financial Reporting – Significant
Deficiency
Federal Program Information
Funding Agency: U.S. Department of Commerce, Minority
Business Development Agency
Federal Award Agreement Number: Not Applicable
Award Year: 2021
Title: MBDA Business Center
CFDA Number: 11.805
Pass‐through Agency: Not Applicable, Direct Program
Pass‐through Identification Number: Not Applicable, Direct Program
Condition ‐ The Entity was unable to provide the annual SF‐424A or provide support it was submitted
on a timely basis. All other reporting under the program was submitted timely and accurately.
Criteria – 2 CFR section 200.303 – Internal Controls of the Uniform Guidance states that the nonfederal
entity must: (a) Establish and maintain effective internal controls over Federal award that
provides reasonable assurance that the non‐Federal entity is managing the Federal award in
compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal
controls should be in compliance with guidance in “Standards for Internal Control in the Federal
Government” issued by the Comptroller General of the United States or the “Internal Control
Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway
Commission (COSO).
Questioned Costs ‐ Not applicable.
Effect ‐ Not submitting an accurate annual report due on a timely basis could result in disallowed
costs.
Cause ‐ The Entity did not have sufficient controls in place to ensure all reporting is submitted to the
grantor agency accurately and on a timely basis, and to retain documentation of the reporting.
2021‐004 – Deficiency in Cash Management Controls over Compliance – Significant Deficiency
Federal Program Information
Funding Agency: U.S. Department of Commerce, Minority
Business Development Agency
Federal Award Agreement Number: Not Applicable
Award Year: 2021
Title: MBDA Business Center
CFDA Number: 11.805
Pass‐through Agency: Not Applicable, Direct Program
Pass‐through Identification Number: Not Applicable, Direct Program
Condition ‐ The Entity does not have policies in procedures to ensure bank reconciliations are being
performed on a timely basis and reviewed and approved by someone other than the person
preparing.
Criteria ‐ 2 CFR section 200.303 – Internal Controls of the Uniform Guidance states that the nonfederal
entity must: (a) Establish and maintain effective internal controls over Federal award that
provides reasonable assurance that the non‐Federal entity is managing the Federal award in
compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
These internal controls should be in compliance with guidance in “Standards for Internal Control in
the Federal Government” issued by the Comptroller General of the United States or the “Internal
Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the
Treadway Commission (COSO).
Questioned Costs ‐ Not applicable.
Effect ‐ Bank reconciliations not performed on a timely manner may not detect misstatements or
errors.
Cause ‐ The Entity does not have proper controls in place to verify federal funds are received for the
amount requested on a timely basis or retain detailed support reconciliations are being performed.
2021‐005 – Deficiency in Special Tests and Provision Controls over Compliance with Training –
Significant Deficiency
Federal Program Information
Funding Agency: U.S. Department of Commerce, Minority
Business Development Agency
Federal Award Agreement Number: Not Applicable
Award Year: 2021
Title: MBDA Business Center
CFDA Number: 11.805
Pass‐through Agency: Not Applicable, Direct Program
Pass‐through Identification Number: Not Applicable, Direct Program
Condition ‐ The Entity was unable to provide support to test controls over compliance over training.
Criteria – 2 CFR section 200.303 – Internal Controls of the Uniform Guidance states that the nonfederal
entity must: (a) Establish and maintain effective internal controls over Federal award that
provides reasonable assurance that the non‐Federal entity is managing the Federal award in
compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
These internal controls should be in compliance with guidance in “Standards for Internal Control in
the Federal Government” issued by the Comptroller General of the United States or the “Internal
Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the
Treadway Commission (COSO).
Questioned Costs ‐ Not applicable.
Effect ‐ The Entity may unintentionally miss a required training which could lead to repayment of
funds.
Cause ‐ The Entity is not following its policy to ensure all mandatory training is completed as needed.
2021‐006 – Deficiencies in Activities Allowed, Allowable Costs, and Period of Performance Controls
over Compliance with Payroll – Significant Deficiency
Federal Program Information
Funding Agency: U.S. Department of Commerce, Minority
Business Development Agency
Federal Award Agreement Number: Not Applicable
Award Year: 2021
Title: MBDA Business Center
CFDA Number: 11.805
Pass‐through Agency: Not Applicable, Direct Program
Pass‐through Identification Number: Not Applicable, Direct Program
Condition ‐ During our review of payroll related transactions, the following were noted
For 5 of the 40 payroll transactions tested, the employee did not have an approved timesheet
or time and effort available for the pay period.
For 3 of the 40 payroll transactions tested, no timesheet or other record of hours worked was
available to support hours paid for the pay period.
For 1 of the 40 payroll transactions tested, employee was not paid for all hours worked on
timesheet.
Criteria – 2 CFR section 200.303 – Internal Controls of the Uniform Guidance states that the nonfederal
entity must: (a) Establish and maintain effective internal controls over Federal award that
provides reasonable assurance that the non‐Federal entity is managing the Federal award in
compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
These internal controls should be in compliance with guidance in “Standards for Internal Control in
the Federal Government” issued by the Comptroller General of the United States or the “Internal
Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the
Treadway Commission (COSO).
Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal
awards for salaries and wages must be based on records that accurately reflect the work performed.
Questioned Costs –$1,010
Effect ‐ The Entity may unintentionally expense employee’s salary out of the federal grant that does
not qualify or under/over compensate what is applicable for the work performed by that employee.
This could lead to questioned costs and repayment of funds to the Grantor agency. Cause ‐ The Entity does not have proper controls in place to verify that documentation was
maintained to indicate the employees’ time paid under the federal grant. Controls were put in place
during the year but were not consistently followed.
2021‐007 – Deficiency in Reporting Controls over Compliance with Financial Reporting – Significant
Deficiency
Federal Program Information
Funding Agency: U.S. Department of Commerce, Minority
Business Development Agency
Federal Award Agreement Number: Not Applicable
Award Year: 2021
Title: MBDA Business Center
CFDA Number: 11.805
Pass‐through Agency: Not Applicable, Direct Program
Pass‐through Identification Number: Not Applicable, Direct Program
Condition ‐ The Entity was unable to provide the annual SF‐424A or provide support it was submitted
on a timely basis. All other reporting under the program was submitted timely and accurately.
Criteria – 2 CFR section 200.303 – Internal Controls of the Uniform Guidance states that the nonfederal
entity must: (a) Establish and maintain effective internal controls over Federal award that
provides reasonable assurance that the non‐Federal entity is managing the Federal award in
compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal
controls should be in compliance with guidance in “Standards for Internal Control in the Federal
Government” issued by the Comptroller General of the United States or the “Internal Control
Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway
Commission (COSO).
Questioned Costs ‐ Not applicable.
Effect ‐ Not submitting an accurate annual report due on a timely basis could result in disallowed
costs.
Cause ‐ The Entity did not have sufficient controls in place to ensure all reporting is submitted to the
grantor agency accurately and on a timely basis, and to retain documentation of the reporting.
2021‐004 – Deficiency in Cash Management Controls over Compliance – Significant Deficiency
Federal Program Information
Funding Agency: U.S. Department of Commerce, Minority
Business Development Agency
Federal Award Agreement Number: Not Applicable
Award Year: 2021
Title: MBDA Business Center
CFDA Number: 11.805
Pass‐through Agency: Not Applicable, Direct Program
Pass‐through Identification Number: Not Applicable, Direct Program
Condition ‐ The Entity does not have policies in procedures to ensure bank reconciliations are being
performed on a timely basis and reviewed and approved by someone other than the person
preparing.
Criteria ‐ 2 CFR section 200.303 – Internal Controls of the Uniform Guidance states that the nonfederal
entity must: (a) Establish and maintain effective internal controls over Federal award that
provides reasonable assurance that the non‐Federal entity is managing the Federal award in
compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
These internal controls should be in compliance with guidance in “Standards for Internal Control in
the Federal Government” issued by the Comptroller General of the United States or the “Internal
Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the
Treadway Commission (COSO).
Questioned Costs ‐ Not applicable.
Effect ‐ Bank reconciliations not performed on a timely manner may not detect misstatements or
errors.
Cause ‐ The Entity does not have proper controls in place to verify federal funds are received for the
amount requested on a timely basis or retain detailed support reconciliations are being performed.
2021‐005 – Deficiency in Special Tests and Provision Controls over Compliance with Training –
Significant Deficiency
Federal Program Information
Funding Agency: U.S. Department of Commerce, Minority
Business Development Agency
Federal Award Agreement Number: Not Applicable
Award Year: 2021
Title: MBDA Business Center
CFDA Number: 11.805
Pass‐through Agency: Not Applicable, Direct Program
Pass‐through Identification Number: Not Applicable, Direct Program
Condition ‐ The Entity was unable to provide support to test controls over compliance over training.
Criteria – 2 CFR section 200.303 – Internal Controls of the Uniform Guidance states that the nonfederal
entity must: (a) Establish and maintain effective internal controls over Federal award that
provides reasonable assurance that the non‐Federal entity is managing the Federal award in
compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
These internal controls should be in compliance with guidance in “Standards for Internal Control in
the Federal Government” issued by the Comptroller General of the United States or the “Internal
Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the
Treadway Commission (COSO).
Questioned Costs ‐ Not applicable.
Effect ‐ The Entity may unintentionally miss a required training which could lead to repayment of
funds.
Cause ‐ The Entity is not following its policy to ensure all mandatory training is completed as needed.
2021‐006 – Deficiencies in Activities Allowed, Allowable Costs, and Period of Performance Controls
over Compliance with Payroll – Significant Deficiency
Federal Program Information
Funding Agency: U.S. Department of Commerce, Minority
Business Development Agency
Federal Award Agreement Number: Not Applicable
Award Year: 2021
Title: MBDA Business Center
CFDA Number: 11.805
Pass‐through Agency: Not Applicable, Direct Program
Pass‐through Identification Number: Not Applicable, Direct Program
Condition ‐ During our review of payroll related transactions, the following were noted
For 5 of the 40 payroll transactions tested, the employee did not have an approved timesheet
or time and effort available for the pay period.
For 3 of the 40 payroll transactions tested, no timesheet or other record of hours worked was
available to support hours paid for the pay period.
For 1 of the 40 payroll transactions tested, employee was not paid for all hours worked on
timesheet.
Criteria – 2 CFR section 200.303 – Internal Controls of the Uniform Guidance states that the nonfederal
entity must: (a) Establish and maintain effective internal controls over Federal award that
provides reasonable assurance that the non‐Federal entity is managing the Federal award in
compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
These internal controls should be in compliance with guidance in “Standards for Internal Control in
the Federal Government” issued by the Comptroller General of the United States or the “Internal
Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the
Treadway Commission (COSO).
Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal
awards for salaries and wages must be based on records that accurately reflect the work performed.
Questioned Costs –$1,010
Effect ‐ The Entity may unintentionally expense employee’s salary out of the federal grant that does
not qualify or under/over compensate what is applicable for the work performed by that employee.
This could lead to questioned costs and repayment of funds to the Grantor agency. Cause ‐ The Entity does not have proper controls in place to verify that documentation was
maintained to indicate the employees’ time paid under the federal grant. Controls were put in place
during the year but were not consistently followed.
2021‐007 – Deficiency in Reporting Controls over Compliance with Financial Reporting – Significant
Deficiency
Federal Program Information
Funding Agency: U.S. Department of Commerce, Minority
Business Development Agency
Federal Award Agreement Number: Not Applicable
Award Year: 2021
Title: MBDA Business Center
CFDA Number: 11.805
Pass‐through Agency: Not Applicable, Direct Program
Pass‐through Identification Number: Not Applicable, Direct Program
Condition ‐ The Entity was unable to provide the annual SF‐424A or provide support it was submitted
on a timely basis. All other reporting under the program was submitted timely and accurately.
Criteria – 2 CFR section 200.303 – Internal Controls of the Uniform Guidance states that the nonfederal
entity must: (a) Establish and maintain effective internal controls over Federal award that
provides reasonable assurance that the non‐Federal entity is managing the Federal award in
compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal
controls should be in compliance with guidance in “Standards for Internal Control in the Federal
Government” issued by the Comptroller General of the United States or the “Internal Control
Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway
Commission (COSO).
Questioned Costs ‐ Not applicable.
Effect ‐ Not submitting an accurate annual report due on a timely basis could result in disallowed
costs.
Cause ‐ The Entity did not have sufficient controls in place to ensure all reporting is submitted to the
grantor agency accurately and on a timely basis, and to retain documentation of the reporting.
2021‐004 – Deficiency in Cash Management Controls over Compliance – Significant Deficiency
Federal Program Information
Funding Agency: U.S. Department of Commerce, Minority
Business Development Agency
Federal Award Agreement Number: Not Applicable
Award Year: 2021
Title: MBDA Business Center
CFDA Number: 11.805
Pass‐through Agency: Not Applicable, Direct Program
Pass‐through Identification Number: Not Applicable, Direct Program
Condition ‐ The Entity does not have policies in procedures to ensure bank reconciliations are being
performed on a timely basis and reviewed and approved by someone other than the person
preparing.
Criteria ‐ 2 CFR section 200.303 – Internal Controls of the Uniform Guidance states that the nonfederal
entity must: (a) Establish and maintain effective internal controls over Federal award that
provides reasonable assurance that the non‐Federal entity is managing the Federal award in
compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
These internal controls should be in compliance with guidance in “Standards for Internal Control in
the Federal Government” issued by the Comptroller General of the United States or the “Internal
Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the
Treadway Commission (COSO).
Questioned Costs ‐ Not applicable.
Effect ‐ Bank reconciliations not performed on a timely manner may not detect misstatements or
errors.
Cause ‐ The Entity does not have proper controls in place to verify federal funds are received for the
amount requested on a timely basis or retain detailed support reconciliations are being performed.
2021‐005 – Deficiency in Special Tests and Provision Controls over Compliance with Training –
Significant Deficiency
Federal Program Information
Funding Agency: U.S. Department of Commerce, Minority
Business Development Agency
Federal Award Agreement Number: Not Applicable
Award Year: 2021
Title: MBDA Business Center
CFDA Number: 11.805
Pass‐through Agency: Not Applicable, Direct Program
Pass‐through Identification Number: Not Applicable, Direct Program
Condition ‐ The Entity was unable to provide support to test controls over compliance over training.
Criteria – 2 CFR section 200.303 – Internal Controls of the Uniform Guidance states that the nonfederal
entity must: (a) Establish and maintain effective internal controls over Federal award that
provides reasonable assurance that the non‐Federal entity is managing the Federal award in
compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
These internal controls should be in compliance with guidance in “Standards for Internal Control in
the Federal Government” issued by the Comptroller General of the United States or the “Internal
Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the
Treadway Commission (COSO).
Questioned Costs ‐ Not applicable.
Effect ‐ The Entity may unintentionally miss a required training which could lead to repayment of
funds.
Cause ‐ The Entity is not following its policy to ensure all mandatory training is completed as needed.
2021‐006 – Deficiencies in Activities Allowed, Allowable Costs, and Period of Performance Controls
over Compliance with Payroll – Significant Deficiency
Federal Program Information
Funding Agency: U.S. Department of Commerce, Minority
Business Development Agency
Federal Award Agreement Number: Not Applicable
Award Year: 2021
Title: MBDA Business Center
CFDA Number: 11.805
Pass‐through Agency: Not Applicable, Direct Program
Pass‐through Identification Number: Not Applicable, Direct Program
Condition ‐ During our review of payroll related transactions, the following were noted
For 5 of the 40 payroll transactions tested, the employee did not have an approved timesheet
or time and effort available for the pay period.
For 3 of the 40 payroll transactions tested, no timesheet or other record of hours worked was
available to support hours paid for the pay period.
For 1 of the 40 payroll transactions tested, employee was not paid for all hours worked on
timesheet.
Criteria – 2 CFR section 200.303 – Internal Controls of the Uniform Guidance states that the nonfederal
entity must: (a) Establish and maintain effective internal controls over Federal award that
provides reasonable assurance that the non‐Federal entity is managing the Federal award in
compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
These internal controls should be in compliance with guidance in “Standards for Internal Control in
the Federal Government” issued by the Comptroller General of the United States or the “Internal
Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the
Treadway Commission (COSO).
Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal
awards for salaries and wages must be based on records that accurately reflect the work performed.
Questioned Costs –$1,010
Effect ‐ The Entity may unintentionally expense employee’s salary out of the federal grant that does
not qualify or under/over compensate what is applicable for the work performed by that employee.
This could lead to questioned costs and repayment of funds to the Grantor agency. Cause ‐ The Entity does not have proper controls in place to verify that documentation was
maintained to indicate the employees’ time paid under the federal grant. Controls were put in place
during the year but were not consistently followed.
2021‐007 – Deficiency in Reporting Controls over Compliance with Financial Reporting – Significant
Deficiency
Federal Program Information
Funding Agency: U.S. Department of Commerce, Minority
Business Development Agency
Federal Award Agreement Number: Not Applicable
Award Year: 2021
Title: MBDA Business Center
CFDA Number: 11.805
Pass‐through Agency: Not Applicable, Direct Program
Pass‐through Identification Number: Not Applicable, Direct Program
Condition ‐ The Entity was unable to provide the annual SF‐424A or provide support it was submitted
on a timely basis. All other reporting under the program was submitted timely and accurately.
Criteria – 2 CFR section 200.303 – Internal Controls of the Uniform Guidance states that the nonfederal
entity must: (a) Establish and maintain effective internal controls over Federal award that
provides reasonable assurance that the non‐Federal entity is managing the Federal award in
compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal
controls should be in compliance with guidance in “Standards for Internal Control in the Federal
Government” issued by the Comptroller General of the United States or the “Internal Control
Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway
Commission (COSO).
Questioned Costs ‐ Not applicable.
Effect ‐ Not submitting an accurate annual report due on a timely basis could result in disallowed
costs.
Cause ‐ The Entity did not have sufficient controls in place to ensure all reporting is submitted to the
grantor agency accurately and on a timely basis, and to retain documentation of the reporting.