Audit 12099

FY End
2022-12-31
Total Expended
$887,266
Findings
8
Programs
3
Year: 2022 Accepted: 2024-01-17

Organization Exclusion Status:

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Findings

ID Ref Severity Repeat Requirement
8834 2022-002 Material Weakness - A
8835 2022-003 Material Weakness - A
8836 2022-004 Material Weakness - A
8837 2022-005 Material Weakness - A
585276 2022-002 Material Weakness - A
585277 2022-003 Material Weakness - A
585278 2022-004 Material Weakness - A
585279 2022-005 Material Weakness - A

Contacts

Name Title Type
WA4VXHKM1N53 Jennifer Auditee
6846990272 Aaron Ready Auditor
No contacts on file

Notes to SEFA

Title: General Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the Schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. De Minimis Rate Used: N Rate Explanation: Expenses (both direct and indirect) not associated with a specific functional classification are allocated among the various classifications using a formula based on staff utilization, or direct payroll hours, in each classification (program, administration, and fundraising). Other costs such as depreciation have been allocated based on management’s estimates of square footage. The accompanying schedule of expenditures of federal awards (the Schedule) includes the federal grant activity of American Samoa Alliance against Domestic & Sexual Violence (Alliance) for the year ended December 31, 2022. The information in this Schedule is presented in accordance with the requirements of 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only a selected portion of the operations of the Alliance, it is not intended to and does not present the financial position, changes in net position, or cash flows of the Alliance. The Alliance did not receive noncash assistance during the year. There were no loans or loan guarantees outstanding.
Title: Summary of Significant Accounting Policies Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the Schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. De Minimis Rate Used: N Rate Explanation: Expenses (both direct and indirect) not associated with a specific functional classification are allocated among the various classifications using a formula based on staff utilization, or direct payroll hours, in each classification (program, administration, and fundraising). Other costs such as depreciation have been allocated based on management’s estimates of square footage. Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the Schedule represent adjustments or credits in the normal course of business to amounts reported as expenditures in prior years.
Title: Indirect Cost Rate Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the Schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. De Minimis Rate Used: N Rate Explanation: Expenses (both direct and indirect) not associated with a specific functional classification are allocated among the various classifications using a formula based on staff utilization, or direct payroll hours, in each classification (program, administration, and fundraising). Other costs such as depreciation have been allocated based on management’s estimates of square footage. The Alliance has elected not to use the 10-percent de minimis indirect cost rate as allowed under the Uniform Guidance.
Title: Contingencies Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the Schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. De Minimis Rate Used: N Rate Explanation: Expenses (both direct and indirect) not associated with a specific functional classification are allocated among the various classifications using a formula based on staff utilization, or direct payroll hours, in each classification (program, administration, and fundraising). Other costs such as depreciation have been allocated based on management’s estimates of square footage. Grant monies received and disbursed by the Alliance are for specific purposes and are subject to review by the grantor agencies. Such audits may result in requests for reimbursement due to disallowed expenditures. Based upon prior experience, the Alliance does not believe that such disallowances, if any would have a material effect on the financial position of the Alliance.

Finding Details

Allowable Costs and Activities Allowed Federal agency: Department of Health and Human Services Federal program title: Family Violence Prevention and Services/State Domestic Violence Coalition Assistance Listing Number: 93.591 Award years: 2021 and 2022 Type of Finding: Material Weakness in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires compliance with allowable cost and activities allowed provisions. The Alliance should have internal controls to ensure compliance with those provisions are complied with. Condition: Extended off island travel was approved by the Board, however documentation indicating the cost savings to the alliance was not maintained. Questioned costs: None. Context: The fiscal policy indicates that extended of island travel is permissible of justifiable cost savings is documented. Cause: The Board approved the extended travel without documented cost savings analysis that is required per the fiscal policy. Effect: A failure to comply with fiscal policies may result in noncompliance with Uniform Guidance allowable cost and activities allowed provisions. Repeat Finding: No Recommendation: We recommend the Alliance maintain support for the cost savings analysis related to extended travel. Views of Responsible Officials: Management agrees. Processes will be put in place to document cost savings in writing when extended travel is necessary. This cost analysis will be filed along with board approval, so it is easily accessible upon request.
Procurement Federal agency: Department of Health and Human Services Federal program title: Family Violence Prevention and Services/State Domestic Violence Coalition Assistance Listing Number: 93.591 Award years: 2021 and 2022 Type of Finding: Material Weakness in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires compliance with procurement provisions. The Alliance should have a policy in place to ensure compliance with procurement provisions. Condition: The Alliance does not have a procurement policy. Questioned costs: None. Context: The island of American Samoa has limited options for procuring goods and services compared to what is available on the mainland. Cause: The Alliance was unaware of the requirements for a procurement policy. Effect: A failure to meet the minimum requirements for procurement in conformity with Uniform Guidance may result in noncompliance and questioned costs. Repeat Finding: No Recommendation: We recommend the Alliance develop a procurement policy that aligns with the requirements of Uniform Guidance. If the Alliance lacks sufficient internal resources, they should consult with an external resource to draft the procurement policy. Views of Responsible Officials: Management agrees. A procurement policy will be developed and added to the finance polices and procedures before end of 2023.
Procurement Federal agency: Department of Health and Human Services Federal program title: Family Violence Prevention and Services/State Domestic Violence Coalition Assistance Listing Number: 93.591 Award year: 2022 Award Number: 2201ASSDVC Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires compliance with reporting provisions. The Alliance should have sufficient policies and procedures in place to ensure compliance with reporting provisions. Condition: The Alliance did not submit on of the 4 required annual reports due during the year under audit. Questioned costs: None. Context: Under the terms and conditions of each grant award, a federal financial report is due annually no later than December 30th for each open project. Cause: The Alliance’s current internal controls were not sufficient to ensure completeness of the reporting population for the year. Effect: A failure to submit the federal financial report results in noncompliance with the requirements of Uniform Guidance. Repeat Finding: No Recommendation: We recommend the Alliance develop a additional policies and procedures that ensure all reporting requirements are met on an annual basis. If the Alliance lacks sufficient internal resources, they should consult with an external resource to draft the procurement policy. Views of Responsible Officials: Management partially agrees. There have been instances when a report will appear for the first time on the PMS website for a period that has already closed, and it shows as delinquent. PMS is checked at least monthly for reports due soon. All of the finance team will add reminders to their calendar, so this is not repeated
Timeliness of Single Audit Completion Type of Finding: Material Noncompliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires compliance with report submission for program-specific audit provisions. 2 CFR 200.507(c)(1) indicates that the audit must be completed and the required reporting submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period, unless a different period is specified in a program-specific audit guide. Condition: The Alliance did not submit the audit within the required timeframe. Questioned costs: None. Context: This is the first year the Alliance was required to have a single audit performed under Uniform Guidance. Cause: The Alliance was unaware of the requirements for timeliness of a single audit. Effect: The Alliance is not in compliance with the federal regulations. Repeat Finding: No Recommendation: We recommend the Alliance continuously monitor it’s expenditures of federal funds and begin the process of engaging an Auditor in a timely manner when the Alliance is aware that it will exceed the threshold triggering a single audit. Views of Responsible Officials: Management partially agrees. While agreeing that the Single Audit was not timely, the Alliance had been trying for a number of months to find an auditor. There is only one CPA on the entire island of American Samoa, and she doesn’t perform audits. There is also the issue of the territory being very remote, in fact, the audit firm performing the audit was several time zones away from American Samoa. Now that the Alliance has a relationship with an audit firm, any Single Audits required in the future will be performed in a timely manner.
Allowable Costs and Activities Allowed Federal agency: Department of Health and Human Services Federal program title: Family Violence Prevention and Services/State Domestic Violence Coalition Assistance Listing Number: 93.591 Award years: 2021 and 2022 Type of Finding: Material Weakness in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires compliance with allowable cost and activities allowed provisions. The Alliance should have internal controls to ensure compliance with those provisions are complied with. Condition: Extended off island travel was approved by the Board, however documentation indicating the cost savings to the alliance was not maintained. Questioned costs: None. Context: The fiscal policy indicates that extended of island travel is permissible of justifiable cost savings is documented. Cause: The Board approved the extended travel without documented cost savings analysis that is required per the fiscal policy. Effect: A failure to comply with fiscal policies may result in noncompliance with Uniform Guidance allowable cost and activities allowed provisions. Repeat Finding: No Recommendation: We recommend the Alliance maintain support for the cost savings analysis related to extended travel. Views of Responsible Officials: Management agrees. Processes will be put in place to document cost savings in writing when extended travel is necessary. This cost analysis will be filed along with board approval, so it is easily accessible upon request.
Procurement Federal agency: Department of Health and Human Services Federal program title: Family Violence Prevention and Services/State Domestic Violence Coalition Assistance Listing Number: 93.591 Award years: 2021 and 2022 Type of Finding: Material Weakness in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires compliance with procurement provisions. The Alliance should have a policy in place to ensure compliance with procurement provisions. Condition: The Alliance does not have a procurement policy. Questioned costs: None. Context: The island of American Samoa has limited options for procuring goods and services compared to what is available on the mainland. Cause: The Alliance was unaware of the requirements for a procurement policy. Effect: A failure to meet the minimum requirements for procurement in conformity with Uniform Guidance may result in noncompliance and questioned costs. Repeat Finding: No Recommendation: We recommend the Alliance develop a procurement policy that aligns with the requirements of Uniform Guidance. If the Alliance lacks sufficient internal resources, they should consult with an external resource to draft the procurement policy. Views of Responsible Officials: Management agrees. A procurement policy will be developed and added to the finance polices and procedures before end of 2023.
Procurement Federal agency: Department of Health and Human Services Federal program title: Family Violence Prevention and Services/State Domestic Violence Coalition Assistance Listing Number: 93.591 Award year: 2022 Award Number: 2201ASSDVC Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires compliance with reporting provisions. The Alliance should have sufficient policies and procedures in place to ensure compliance with reporting provisions. Condition: The Alliance did not submit on of the 4 required annual reports due during the year under audit. Questioned costs: None. Context: Under the terms and conditions of each grant award, a federal financial report is due annually no later than December 30th for each open project. Cause: The Alliance’s current internal controls were not sufficient to ensure completeness of the reporting population for the year. Effect: A failure to submit the federal financial report results in noncompliance with the requirements of Uniform Guidance. Repeat Finding: No Recommendation: We recommend the Alliance develop a additional policies and procedures that ensure all reporting requirements are met on an annual basis. If the Alliance lacks sufficient internal resources, they should consult with an external resource to draft the procurement policy. Views of Responsible Officials: Management partially agrees. There have been instances when a report will appear for the first time on the PMS website for a period that has already closed, and it shows as delinquent. PMS is checked at least monthly for reports due soon. All of the finance team will add reminders to their calendar, so this is not repeated
Timeliness of Single Audit Completion Type of Finding: Material Noncompliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires compliance with report submission for program-specific audit provisions. 2 CFR 200.507(c)(1) indicates that the audit must be completed and the required reporting submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period, unless a different period is specified in a program-specific audit guide. Condition: The Alliance did not submit the audit within the required timeframe. Questioned costs: None. Context: This is the first year the Alliance was required to have a single audit performed under Uniform Guidance. Cause: The Alliance was unaware of the requirements for timeliness of a single audit. Effect: The Alliance is not in compliance with the federal regulations. Repeat Finding: No Recommendation: We recommend the Alliance continuously monitor it’s expenditures of federal funds and begin the process of engaging an Auditor in a timely manner when the Alliance is aware that it will exceed the threshold triggering a single audit. Views of Responsible Officials: Management partially agrees. While agreeing that the Single Audit was not timely, the Alliance had been trying for a number of months to find an auditor. There is only one CPA on the entire island of American Samoa, and she doesn’t perform audits. There is also the issue of the territory being very remote, in fact, the audit firm performing the audit was several time zones away from American Samoa. Now that the Alliance has a relationship with an audit firm, any Single Audits required in the future will be performed in a timely manner.