Audit 16547

FY End
2022-06-30
Total Expended
$3.80M
Findings
8
Programs
1
Organization: Epilepsy Foundation of America (MD)
Year: 2022 Accepted: 2023-02-13

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
12263 2022-002 Material Weakness - L
12264 2022-003 - - L
12265 2022-004 Material Weakness - AB
12266 2022-005 Material Weakness - BC
588705 2022-002 Material Weakness - L
588706 2022-003 - - L
588707 2022-004 Material Weakness - AB
588708 2022-005 Material Weakness - BC

Programs

ALN Program Spent Major Findings
93.850 Improving Epilepsy Programs, Services, and Outcomes Through National Partnerships $3.80M Yes 4

Contacts

Name Title Type
SPY7BAJM1AN9 Caro Brown Auditee
3019183752 Paul Preziotti Auditor
No contacts on file

Notes to SEFA

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 Title 2 U.S. CFR Part 200, Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Pass-through entity identifying numbers are presented where available. The Foundation has elected not to use the 10-percent de minimis indirect cost rate as allowed under the Uniform Guidance. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate.

Finding Details

Finding 2022-002: Material Weakness over Reporting - Review of Required Financial and Progress Reports Information on the Federal Program: Department of Human and Health - Center for Disease Control: Improving Epilepsy Programs, Services and Outcomes Through Partnerships, CFDA 93.850 Criteria: The Uniform Guidance requires organizations to establish internal controls to detect potential noncompliance. Condition: Management has an established control in place in that the VP of Finance reviews the financial and progress reports prior to submission, but did not retain evidence of this review occurring during the year. Cause: Due to a lack of policies and procedures regarding retention of review documentation and lack of awareness of the requirement. Effect: Non-compliance with adequate review over required financial and progress reports. Questioned Costs: There were no material questioned costs identified. Context: For all reports chosen for testing in 2022, which included two quarterly FFRs (Federal Financial Report), an annual FFR, and an annual performance progress report, no evidence of approval was retained. Repeat Finding: No. Recommendation: We recommend that management establish procedures to document the review and approval performed over the required reports.
Finding 2022-003: Non-Compliance over Reporting - Reporting of Expenditures in Required Financial Reports Information on the Federal Program: Department of Human and Health - Center for Disease Control: Improving Epilepsy Programs, Services and Outcomes Through Partnerships, CFDA 93.850 Criteria: The Uniform Guidance requires organizations to submit required financial reports with accurate data pertaining to expenditures. Condition: The underlying expenditures support provided for the quarterly and annual Federal Financial Report (FFRs) did not tie to the expenditures reported. Cause: Due to a lack of effective review over required financial reports. Effect: Non-compliance with accuracy of amounts reported in required financial reports. Questioned Costs: There were no material questioned costs identified. Context: For all financial reports chosen for testing in 2022, which included two quarterly FFR and an annual FFR, the underlying expenditures support provided did not tie to the expenditures reported with a variance of $67,890. Repeat Finding: No. Recommendation: We recommend that management establish procedures to review and the financial reports in detail to ensure accuracy to underlying data.
Finding 2022-004: Material Weakness over Allowable Costs - Review of Non-Payroll Expenditures Information on the Federal Program: Department of Human and Health - Center for Disease Control: Improving Epilepsy Programs, Services and Outcomes Through Partnerships, CFDA 93.850 Criteria: The Uniform Guidance requires organizations to establish internal controls to detect potential noncompliance. Condition: Management has an established control in place, in that all expenditures paid through the Concur system were reviewed and approved by an appropriate project manager, but did not retain evidence of this approval occurring during the year for 9 non-payroll expenditures chosen for testing. Cause: Due to a lack of policies and procedures regarding retention of review documentation and lack of awareness of the requirement. Effect: Non-compliance with adequate review over allowable costs. Questioned Costs: There were no material questioned costs identified. Context: All expenditures approved in the Concur payables system chosen for testing did not have retained evidence of approval, totaling 15% of the non-payroll expenditures tested. Repeat Finding: No. Recommendation: We recommend that management establish procedures to document the review and approval performed over non-payroll expenditures.
Finding 2022-005: Material Weakness over Cash Management and Allowable Costs - Review of Cash Drawdowns Information on the Federal Program: Department of Human and Health - Center for Disease Control: Improving Epilepsy Programs, Services and Outcomes Through Partnerships, CFDA 93.850 Criteria: The Uniform Guidance requires organizations to establish internal controls to detect potential noncompliance. The Uniform Guidance also requires organizations who receive funds on a cost reimbursement basis to only draw down funds for allowable expenditures under the grant. Condition: Management has an established control in place, in that the VP of Finance reviews the calculation of expenditures not drawn down prior to the submission of the drawdown request. However, the control was ineffective to prevent and detect an erroneous expense journal entry, considered an unallowable expense and is an instance of noncompliance, from being included in the drawdown. Cause: Due to a lack of policies and procedures regarding retention of review documentation and lack of awareness of the requirement. Effect: Non-compliance with adequate review over cash management and allowable costs. Questioned Costs: $72,514 in known questioned costs were identified, as determined by management as a part of an inspection performed. Context: For one cash drawdown chosen for testing of two (50%), there were expenses that had no supporting documentation and were unallowable under the grant. Repeat Finding: No. Recommendation: We recommend that management establish procedures review cash drawdowns in detail prior to submission and that all expenditures recorded to the grant have appropriate supporting documentation.
Finding 2022-002: Material Weakness over Reporting - Review of Required Financial and Progress Reports Information on the Federal Program: Department of Human and Health - Center for Disease Control: Improving Epilepsy Programs, Services and Outcomes Through Partnerships, CFDA 93.850 Criteria: The Uniform Guidance requires organizations to establish internal controls to detect potential noncompliance. Condition: Management has an established control in place in that the VP of Finance reviews the financial and progress reports prior to submission, but did not retain evidence of this review occurring during the year. Cause: Due to a lack of policies and procedures regarding retention of review documentation and lack of awareness of the requirement. Effect: Non-compliance with adequate review over required financial and progress reports. Questioned Costs: There were no material questioned costs identified. Context: For all reports chosen for testing in 2022, which included two quarterly FFRs (Federal Financial Report), an annual FFR, and an annual performance progress report, no evidence of approval was retained. Repeat Finding: No. Recommendation: We recommend that management establish procedures to document the review and approval performed over the required reports.
Finding 2022-003: Non-Compliance over Reporting - Reporting of Expenditures in Required Financial Reports Information on the Federal Program: Department of Human and Health - Center for Disease Control: Improving Epilepsy Programs, Services and Outcomes Through Partnerships, CFDA 93.850 Criteria: The Uniform Guidance requires organizations to submit required financial reports with accurate data pertaining to expenditures. Condition: The underlying expenditures support provided for the quarterly and annual Federal Financial Report (FFRs) did not tie to the expenditures reported. Cause: Due to a lack of effective review over required financial reports. Effect: Non-compliance with accuracy of amounts reported in required financial reports. Questioned Costs: There were no material questioned costs identified. Context: For all financial reports chosen for testing in 2022, which included two quarterly FFR and an annual FFR, the underlying expenditures support provided did not tie to the expenditures reported with a variance of $67,890. Repeat Finding: No. Recommendation: We recommend that management establish procedures to review and the financial reports in detail to ensure accuracy to underlying data.
Finding 2022-004: Material Weakness over Allowable Costs - Review of Non-Payroll Expenditures Information on the Federal Program: Department of Human and Health - Center for Disease Control: Improving Epilepsy Programs, Services and Outcomes Through Partnerships, CFDA 93.850 Criteria: The Uniform Guidance requires organizations to establish internal controls to detect potential noncompliance. Condition: Management has an established control in place, in that all expenditures paid through the Concur system were reviewed and approved by an appropriate project manager, but did not retain evidence of this approval occurring during the year for 9 non-payroll expenditures chosen for testing. Cause: Due to a lack of policies and procedures regarding retention of review documentation and lack of awareness of the requirement. Effect: Non-compliance with adequate review over allowable costs. Questioned Costs: There were no material questioned costs identified. Context: All expenditures approved in the Concur payables system chosen for testing did not have retained evidence of approval, totaling 15% of the non-payroll expenditures tested. Repeat Finding: No. Recommendation: We recommend that management establish procedures to document the review and approval performed over non-payroll expenditures.
Finding 2022-005: Material Weakness over Cash Management and Allowable Costs - Review of Cash Drawdowns Information on the Federal Program: Department of Human and Health - Center for Disease Control: Improving Epilepsy Programs, Services and Outcomes Through Partnerships, CFDA 93.850 Criteria: The Uniform Guidance requires organizations to establish internal controls to detect potential noncompliance. The Uniform Guidance also requires organizations who receive funds on a cost reimbursement basis to only draw down funds for allowable expenditures under the grant. Condition: Management has an established control in place, in that the VP of Finance reviews the calculation of expenditures not drawn down prior to the submission of the drawdown request. However, the control was ineffective to prevent and detect an erroneous expense journal entry, considered an unallowable expense and is an instance of noncompliance, from being included in the drawdown. Cause: Due to a lack of policies and procedures regarding retention of review documentation and lack of awareness of the requirement. Effect: Non-compliance with adequate review over cash management and allowable costs. Questioned Costs: $72,514 in known questioned costs were identified, as determined by management as a part of an inspection performed. Context: For one cash drawdown chosen for testing of two (50%), there were expenses that had no supporting documentation and were unallowable under the grant. Repeat Finding: No. Recommendation: We recommend that management establish procedures review cash drawdowns in detail prior to submission and that all expenditures recorded to the grant have appropriate supporting documentation.