2022-003 U.S. Department of Justice Federal Financial Assistance Listing #16.575 Victims of Crime Act (VOCA) Cash Management Significant Deficiency in Internal Control over Compliance Criteria - A good system of internal control over compliance related to a program?s cash management policies should require a review of the cash draw by a second individual and documentation of the review should be properly retained by the Organization. Condition - During the course of our engagement, we identified that there was no observable documentation being consistently retained to indicate that a review of the cash draws was being performed prior to submission. Cause ? Reviews surrounding the preparation and draws of federal funds prior to submission were not properly documented and retained by the Organization. Effect - Without proper documentation, it is difficult to determine that a secondary review of the cash draws occurred. This could result in Organization drawing funds in inappropriate amounts or for unallowed costs. Questioned Costs - None reported Context/Sampling - A sample of eight cash draws out of a population of twenty-four were selected. Four of the eight cash draws selected for testing did not have evidence of review. of the items in the sample showed evidence of review. Repeat Finding from Prior Year ? Yes, Finding 2021-003 Recommendation - We recommend that a member of the Organization?s staff who does not prepare the cash draw review the cash draw prior to submission and document that review. The documentation of the review should be retained. Views of Responsible Officials - Management agrees with the finding.
2022-004 U.S. Department of Justice Federal Financial Assistance Listing #16.575 Victims of Crime Act (VOCA) Procurement, Suspension and Debarment Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria - Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) Sections 200.318 through 200.326 set forth the procurement standards non-federal entities other than states must follow when operating federal programs and the procurement procedures required depending on the dollar amount of the transaction. Condition - During the course of our engagement, we identified that there was no observable documentation to indicate that the required procurement procedures were performed on vendors. Cause - Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and all applicable CFR sections and controls were not adequately designed to ensure compliance with all of these requirements. Effect - A lack of established controls increases the overall risk that the Organization is contracting and awarding contracts which may not be the most cost advantageous. Questioned Costs - None reported Context/Sampling - A sample of 9 expenditures out of a population of 12 expenditures were selected for testing. Four of these met the conditions of the procurement policy (i.e., non- payroll related expenditures) and did not have the supporting documentation retained due to having entered into the contract during 2020 or prior to the implementation of the procurement policy in 2020. Two of these met the conditions of the procurement policy (i.e., non-payroll related expenditures) and did not go through the Organization?s procurement policy. Repeat Finding from Prior Year ? Yes, Finding 2021-004 Recommendation - We recommend that the Organization maintain the appropriate documentation evidencing that procurement procedures have been completed. Views of Responsible Officials - Management agrees with the finding.
2022-005 U.S. Department of Justice Federal Financial Assistance Listing #16.575 Victims of Crime Act (VOCA) Activities Allowed or Unallowed and Allowable Costs/Cost Principles Significant Deficiency in Internal Control over Compliance Criteria - The Organization allocates various expenditures to several grants, generally using a predetermined percentage split. However, the Organization does have some ability to change the allocation given specific facts and circumstances. Condition - During the course of our engagement, we noted instances where the allocation did not follow the predetermined percentage split, but the allocation methodology and the reason for the allocation not following the predetermine percentage split was not documented. Cause - The grant does allow for changes to the allocation of certain expenditures. However, management was not documenting the reasons for the different allocation methods being used if the predetermine percentage split was not being followed. Effect - Without proper documentation, it is difficult to determine that a reasonable allocation of expenditures occurred. This could result in the granting agencies questioning the allocations and management may not be able to reproduce the methodology or explain the allocation methodology being used. Questioned Costs - None reported Context/Sampling - A sample of 60 expenditures out of over 1,100 expenditures were selected for testing. Ten allocations did not follow the predetermined percentage split and had limited documentation as to the allocation methodology being used. Repeat Finding from Prior Year ? Yes, 2021-005 Recommendation - We recommend that the Organization document the allocation methodology being used for expenditures that relate to more than one grant, especially in cases where the predetermined allocation percentage is not being used. Views of Responsible Officials - Management agrees with the finding.
2022-003 U.S. Department of Justice Federal Financial Assistance Listing #16.575 Victims of Crime Act (VOCA) Cash Management Significant Deficiency in Internal Control over Compliance Criteria - A good system of internal control over compliance related to a program?s cash management policies should require a review of the cash draw by a second individual and documentation of the review should be properly retained by the Organization. Condition - During the course of our engagement, we identified that there was no observable documentation being consistently retained to indicate that a review of the cash draws was being performed prior to submission. Cause ? Reviews surrounding the preparation and draws of federal funds prior to submission were not properly documented and retained by the Organization. Effect - Without proper documentation, it is difficult to determine that a secondary review of the cash draws occurred. This could result in Organization drawing funds in inappropriate amounts or for unallowed costs. Questioned Costs - None reported Context/Sampling - A sample of eight cash draws out of a population of twenty-four were selected. Four of the eight cash draws selected for testing did not have evidence of review. of the items in the sample showed evidence of review. Repeat Finding from Prior Year ? Yes, Finding 2021-003 Recommendation - We recommend that a member of the Organization?s staff who does not prepare the cash draw review the cash draw prior to submission and document that review. The documentation of the review should be retained. Views of Responsible Officials - Management agrees with the finding.
2022-004 U.S. Department of Justice Federal Financial Assistance Listing #16.575 Victims of Crime Act (VOCA) Procurement, Suspension and Debarment Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria - Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) Sections 200.318 through 200.326 set forth the procurement standards non-federal entities other than states must follow when operating federal programs and the procurement procedures required depending on the dollar amount of the transaction. Condition - During the course of our engagement, we identified that there was no observable documentation to indicate that the required procurement procedures were performed on vendors. Cause - Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and all applicable CFR sections and controls were not adequately designed to ensure compliance with all of these requirements. Effect - A lack of established controls increases the overall risk that the Organization is contracting and awarding contracts which may not be the most cost advantageous. Questioned Costs - None reported Context/Sampling - A sample of 9 expenditures out of a population of 12 expenditures were selected for testing. Four of these met the conditions of the procurement policy (i.e., non- payroll related expenditures) and did not have the supporting documentation retained due to having entered into the contract during 2020 or prior to the implementation of the procurement policy in 2020. Two of these met the conditions of the procurement policy (i.e., non-payroll related expenditures) and did not go through the Organization?s procurement policy. Repeat Finding from Prior Year ? Yes, Finding 2021-004 Recommendation - We recommend that the Organization maintain the appropriate documentation evidencing that procurement procedures have been completed. Views of Responsible Officials - Management agrees with the finding.
2022-005 U.S. Department of Justice Federal Financial Assistance Listing #16.575 Victims of Crime Act (VOCA) Activities Allowed or Unallowed and Allowable Costs/Cost Principles Significant Deficiency in Internal Control over Compliance Criteria - The Organization allocates various expenditures to several grants, generally using a predetermined percentage split. However, the Organization does have some ability to change the allocation given specific facts and circumstances. Condition - During the course of our engagement, we noted instances where the allocation did not follow the predetermined percentage split, but the allocation methodology and the reason for the allocation not following the predetermine percentage split was not documented. Cause - The grant does allow for changes to the allocation of certain expenditures. However, management was not documenting the reasons for the different allocation methods being used if the predetermine percentage split was not being followed. Effect - Without proper documentation, it is difficult to determine that a reasonable allocation of expenditures occurred. This could result in the granting agencies questioning the allocations and management may not be able to reproduce the methodology or explain the allocation methodology being used. Questioned Costs - None reported Context/Sampling - A sample of 60 expenditures out of over 1,100 expenditures were selected for testing. Ten allocations did not follow the predetermined percentage split and had limited documentation as to the allocation methodology being used. Repeat Finding from Prior Year ? Yes, 2021-005 Recommendation - We recommend that the Organization document the allocation methodology being used for expenditures that relate to more than one grant, especially in cases where the predetermined allocation percentage is not being used. Views of Responsible Officials - Management agrees with the finding.
2022-003 U.S. Department of Justice Federal Financial Assistance Listing #16.575 Victims of Crime Act (VOCA) Cash Management Significant Deficiency in Internal Control over Compliance Criteria - A good system of internal control over compliance related to a program?s cash management policies should require a review of the cash draw by a second individual and documentation of the review should be properly retained by the Organization. Condition - During the course of our engagement, we identified that there was no observable documentation being consistently retained to indicate that a review of the cash draws was being performed prior to submission. Cause ? Reviews surrounding the preparation and draws of federal funds prior to submission were not properly documented and retained by the Organization. Effect - Without proper documentation, it is difficult to determine that a secondary review of the cash draws occurred. This could result in Organization drawing funds in inappropriate amounts or for unallowed costs. Questioned Costs - None reported Context/Sampling - A sample of eight cash draws out of a population of twenty-four were selected. Four of the eight cash draws selected for testing did not have evidence of review. of the items in the sample showed evidence of review. Repeat Finding from Prior Year ? Yes, Finding 2021-003 Recommendation - We recommend that a member of the Organization?s staff who does not prepare the cash draw review the cash draw prior to submission and document that review. The documentation of the review should be retained. Views of Responsible Officials - Management agrees with the finding.
2022-004 U.S. Department of Justice Federal Financial Assistance Listing #16.575 Victims of Crime Act (VOCA) Procurement, Suspension and Debarment Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria - Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) Sections 200.318 through 200.326 set forth the procurement standards non-federal entities other than states must follow when operating federal programs and the procurement procedures required depending on the dollar amount of the transaction. Condition - During the course of our engagement, we identified that there was no observable documentation to indicate that the required procurement procedures were performed on vendors. Cause - Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and all applicable CFR sections and controls were not adequately designed to ensure compliance with all of these requirements. Effect - A lack of established controls increases the overall risk that the Organization is contracting and awarding contracts which may not be the most cost advantageous. Questioned Costs - None reported Context/Sampling - A sample of 9 expenditures out of a population of 12 expenditures were selected for testing. Four of these met the conditions of the procurement policy (i.e., non- payroll related expenditures) and did not have the supporting documentation retained due to having entered into the contract during 2020 or prior to the implementation of the procurement policy in 2020. Two of these met the conditions of the procurement policy (i.e., non-payroll related expenditures) and did not go through the Organization?s procurement policy. Repeat Finding from Prior Year ? Yes, Finding 2021-004 Recommendation - We recommend that the Organization maintain the appropriate documentation evidencing that procurement procedures have been completed. Views of Responsible Officials - Management agrees with the finding.
2022-005 U.S. Department of Justice Federal Financial Assistance Listing #16.575 Victims of Crime Act (VOCA) Activities Allowed or Unallowed and Allowable Costs/Cost Principles Significant Deficiency in Internal Control over Compliance Criteria - The Organization allocates various expenditures to several grants, generally using a predetermined percentage split. However, the Organization does have some ability to change the allocation given specific facts and circumstances. Condition - During the course of our engagement, we noted instances where the allocation did not follow the predetermined percentage split, but the allocation methodology and the reason for the allocation not following the predetermine percentage split was not documented. Cause - The grant does allow for changes to the allocation of certain expenditures. However, management was not documenting the reasons for the different allocation methods being used if the predetermine percentage split was not being followed. Effect - Without proper documentation, it is difficult to determine that a reasonable allocation of expenditures occurred. This could result in the granting agencies questioning the allocations and management may not be able to reproduce the methodology or explain the allocation methodology being used. Questioned Costs - None reported Context/Sampling - A sample of 60 expenditures out of over 1,100 expenditures were selected for testing. Ten allocations did not follow the predetermined percentage split and had limited documentation as to the allocation methodology being used. Repeat Finding from Prior Year ? Yes, 2021-005 Recommendation - We recommend that the Organization document the allocation methodology being used for expenditures that relate to more than one grant, especially in cases where the predetermined allocation percentage is not being used. Views of Responsible Officials - Management agrees with the finding.
2022-003 U.S. Department of Justice Federal Financial Assistance Listing #16.575 Victims of Crime Act (VOCA) Cash Management Significant Deficiency in Internal Control over Compliance Criteria - A good system of internal control over compliance related to a program?s cash management policies should require a review of the cash draw by a second individual and documentation of the review should be properly retained by the Organization. Condition - During the course of our engagement, we identified that there was no observable documentation being consistently retained to indicate that a review of the cash draws was being performed prior to submission. Cause ? Reviews surrounding the preparation and draws of federal funds prior to submission were not properly documented and retained by the Organization. Effect - Without proper documentation, it is difficult to determine that a secondary review of the cash draws occurred. This could result in Organization drawing funds in inappropriate amounts or for unallowed costs. Questioned Costs - None reported Context/Sampling - A sample of eight cash draws out of a population of twenty-four were selected. Four of the eight cash draws selected for testing did not have evidence of review. of the items in the sample showed evidence of review. Repeat Finding from Prior Year ? Yes, Finding 2021-003 Recommendation - We recommend that a member of the Organization?s staff who does not prepare the cash draw review the cash draw prior to submission and document that review. The documentation of the review should be retained. Views of Responsible Officials - Management agrees with the finding.
2022-004 U.S. Department of Justice Federal Financial Assistance Listing #16.575 Victims of Crime Act (VOCA) Procurement, Suspension and Debarment Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria - Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) Sections 200.318 through 200.326 set forth the procurement standards non-federal entities other than states must follow when operating federal programs and the procurement procedures required depending on the dollar amount of the transaction. Condition - During the course of our engagement, we identified that there was no observable documentation to indicate that the required procurement procedures were performed on vendors. Cause - Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and all applicable CFR sections and controls were not adequately designed to ensure compliance with all of these requirements. Effect - A lack of established controls increases the overall risk that the Organization is contracting and awarding contracts which may not be the most cost advantageous. Questioned Costs - None reported Context/Sampling - A sample of 9 expenditures out of a population of 12 expenditures were selected for testing. Four of these met the conditions of the procurement policy (i.e., non- payroll related expenditures) and did not have the supporting documentation retained due to having entered into the contract during 2020 or prior to the implementation of the procurement policy in 2020. Two of these met the conditions of the procurement policy (i.e., non-payroll related expenditures) and did not go through the Organization?s procurement policy. Repeat Finding from Prior Year ? Yes, Finding 2021-004 Recommendation - We recommend that the Organization maintain the appropriate documentation evidencing that procurement procedures have been completed. Views of Responsible Officials - Management agrees with the finding.
2022-005 U.S. Department of Justice Federal Financial Assistance Listing #16.575 Victims of Crime Act (VOCA) Activities Allowed or Unallowed and Allowable Costs/Cost Principles Significant Deficiency in Internal Control over Compliance Criteria - The Organization allocates various expenditures to several grants, generally using a predetermined percentage split. However, the Organization does have some ability to change the allocation given specific facts and circumstances. Condition - During the course of our engagement, we noted instances where the allocation did not follow the predetermined percentage split, but the allocation methodology and the reason for the allocation not following the predetermine percentage split was not documented. Cause - The grant does allow for changes to the allocation of certain expenditures. However, management was not documenting the reasons for the different allocation methods being used if the predetermine percentage split was not being followed. Effect - Without proper documentation, it is difficult to determine that a reasonable allocation of expenditures occurred. This could result in the granting agencies questioning the allocations and management may not be able to reproduce the methodology or explain the allocation methodology being used. Questioned Costs - None reported Context/Sampling - A sample of 60 expenditures out of over 1,100 expenditures were selected for testing. Ten allocations did not follow the predetermined percentage split and had limited documentation as to the allocation methodology being used. Repeat Finding from Prior Year ? Yes, 2021-005 Recommendation - We recommend that the Organization document the allocation methodology being used for expenditures that relate to more than one grant, especially in cases where the predetermined allocation percentage is not being used. Views of Responsible Officials - Management agrees with the finding.
2022-003 U.S. Department of Justice Federal Financial Assistance Listing #16.575 Victims of Crime Act (VOCA) Cash Management Significant Deficiency in Internal Control over Compliance Criteria - A good system of internal control over compliance related to a program?s cash management policies should require a review of the cash draw by a second individual and documentation of the review should be properly retained by the Organization. Condition - During the course of our engagement, we identified that there was no observable documentation being consistently retained to indicate that a review of the cash draws was being performed prior to submission. Cause ? Reviews surrounding the preparation and draws of federal funds prior to submission were not properly documented and retained by the Organization. Effect - Without proper documentation, it is difficult to determine that a secondary review of the cash draws occurred. This could result in Organization drawing funds in inappropriate amounts or for unallowed costs. Questioned Costs - None reported Context/Sampling - A sample of eight cash draws out of a population of twenty-four were selected. Four of the eight cash draws selected for testing did not have evidence of review. of the items in the sample showed evidence of review. Repeat Finding from Prior Year ? Yes, Finding 2021-003 Recommendation - We recommend that a member of the Organization?s staff who does not prepare the cash draw review the cash draw prior to submission and document that review. The documentation of the review should be retained. Views of Responsible Officials - Management agrees with the finding.
2022-004 U.S. Department of Justice Federal Financial Assistance Listing #16.575 Victims of Crime Act (VOCA) Procurement, Suspension and Debarment Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria - Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) Sections 200.318 through 200.326 set forth the procurement standards non-federal entities other than states must follow when operating federal programs and the procurement procedures required depending on the dollar amount of the transaction. Condition - During the course of our engagement, we identified that there was no observable documentation to indicate that the required procurement procedures were performed on vendors. Cause - Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and all applicable CFR sections and controls were not adequately designed to ensure compliance with all of these requirements. Effect - A lack of established controls increases the overall risk that the Organization is contracting and awarding contracts which may not be the most cost advantageous. Questioned Costs - None reported Context/Sampling - A sample of 9 expenditures out of a population of 12 expenditures were selected for testing. Four of these met the conditions of the procurement policy (i.e., non- payroll related expenditures) and did not have the supporting documentation retained due to having entered into the contract during 2020 or prior to the implementation of the procurement policy in 2020. Two of these met the conditions of the procurement policy (i.e., non-payroll related expenditures) and did not go through the Organization?s procurement policy. Repeat Finding from Prior Year ? Yes, Finding 2021-004 Recommendation - We recommend that the Organization maintain the appropriate documentation evidencing that procurement procedures have been completed. Views of Responsible Officials - Management agrees with the finding.
2022-005 U.S. Department of Justice Federal Financial Assistance Listing #16.575 Victims of Crime Act (VOCA) Activities Allowed or Unallowed and Allowable Costs/Cost Principles Significant Deficiency in Internal Control over Compliance Criteria - The Organization allocates various expenditures to several grants, generally using a predetermined percentage split. However, the Organization does have some ability to change the allocation given specific facts and circumstances. Condition - During the course of our engagement, we noted instances where the allocation did not follow the predetermined percentage split, but the allocation methodology and the reason for the allocation not following the predetermine percentage split was not documented. Cause - The grant does allow for changes to the allocation of certain expenditures. However, management was not documenting the reasons for the different allocation methods being used if the predetermine percentage split was not being followed. Effect - Without proper documentation, it is difficult to determine that a reasonable allocation of expenditures occurred. This could result in the granting agencies questioning the allocations and management may not be able to reproduce the methodology or explain the allocation methodology being used. Questioned Costs - None reported Context/Sampling - A sample of 60 expenditures out of over 1,100 expenditures were selected for testing. Ten allocations did not follow the predetermined percentage split and had limited documentation as to the allocation methodology being used. Repeat Finding from Prior Year ? Yes, 2021-005 Recommendation - We recommend that the Organization document the allocation methodology being used for expenditures that relate to more than one grant, especially in cases where the predetermined allocation percentage is not being used. Views of Responsible Officials - Management agrees with the finding.
2022-003 U.S. Department of Justice Federal Financial Assistance Listing #16.575 Victims of Crime Act (VOCA) Cash Management Significant Deficiency in Internal Control over Compliance Criteria - A good system of internal control over compliance related to a program?s cash management policies should require a review of the cash draw by a second individual and documentation of the review should be properly retained by the Organization. Condition - During the course of our engagement, we identified that there was no observable documentation being consistently retained to indicate that a review of the cash draws was being performed prior to submission. Cause ? Reviews surrounding the preparation and draws of federal funds prior to submission were not properly documented and retained by the Organization. Effect - Without proper documentation, it is difficult to determine that a secondary review of the cash draws occurred. This could result in Organization drawing funds in inappropriate amounts or for unallowed costs. Questioned Costs - None reported Context/Sampling - A sample of eight cash draws out of a population of twenty-four were selected. Four of the eight cash draws selected for testing did not have evidence of review. of the items in the sample showed evidence of review. Repeat Finding from Prior Year ? Yes, Finding 2021-003 Recommendation - We recommend that a member of the Organization?s staff who does not prepare the cash draw review the cash draw prior to submission and document that review. The documentation of the review should be retained. Views of Responsible Officials - Management agrees with the finding.
2022-004 U.S. Department of Justice Federal Financial Assistance Listing #16.575 Victims of Crime Act (VOCA) Procurement, Suspension and Debarment Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria - Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) Sections 200.318 through 200.326 set forth the procurement standards non-federal entities other than states must follow when operating federal programs and the procurement procedures required depending on the dollar amount of the transaction. Condition - During the course of our engagement, we identified that there was no observable documentation to indicate that the required procurement procedures were performed on vendors. Cause - Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and all applicable CFR sections and controls were not adequately designed to ensure compliance with all of these requirements. Effect - A lack of established controls increases the overall risk that the Organization is contracting and awarding contracts which may not be the most cost advantageous. Questioned Costs - None reported Context/Sampling - A sample of 9 expenditures out of a population of 12 expenditures were selected for testing. Four of these met the conditions of the procurement policy (i.e., non- payroll related expenditures) and did not have the supporting documentation retained due to having entered into the contract during 2020 or prior to the implementation of the procurement policy in 2020. Two of these met the conditions of the procurement policy (i.e., non-payroll related expenditures) and did not go through the Organization?s procurement policy. Repeat Finding from Prior Year ? Yes, Finding 2021-004 Recommendation - We recommend that the Organization maintain the appropriate documentation evidencing that procurement procedures have been completed. Views of Responsible Officials - Management agrees with the finding.
2022-005 U.S. Department of Justice Federal Financial Assistance Listing #16.575 Victims of Crime Act (VOCA) Activities Allowed or Unallowed and Allowable Costs/Cost Principles Significant Deficiency in Internal Control over Compliance Criteria - The Organization allocates various expenditures to several grants, generally using a predetermined percentage split. However, the Organization does have some ability to change the allocation given specific facts and circumstances. Condition - During the course of our engagement, we noted instances where the allocation did not follow the predetermined percentage split, but the allocation methodology and the reason for the allocation not following the predetermine percentage split was not documented. Cause - The grant does allow for changes to the allocation of certain expenditures. However, management was not documenting the reasons for the different allocation methods being used if the predetermine percentage split was not being followed. Effect - Without proper documentation, it is difficult to determine that a reasonable allocation of expenditures occurred. This could result in the granting agencies questioning the allocations and management may not be able to reproduce the methodology or explain the allocation methodology being used. Questioned Costs - None reported Context/Sampling - A sample of 60 expenditures out of over 1,100 expenditures were selected for testing. Ten allocations did not follow the predetermined percentage split and had limited documentation as to the allocation methodology being used. Repeat Finding from Prior Year ? Yes, 2021-005 Recommendation - We recommend that the Organization document the allocation methodology being used for expenditures that relate to more than one grant, especially in cases where the predetermined allocation percentage is not being used. Views of Responsible Officials - Management agrees with the finding.
2022-003 U.S. Department of Justice Federal Financial Assistance Listing #16.575 Victims of Crime Act (VOCA) Cash Management Significant Deficiency in Internal Control over Compliance Criteria - A good system of internal control over compliance related to a program?s cash management policies should require a review of the cash draw by a second individual and documentation of the review should be properly retained by the Organization. Condition - During the course of our engagement, we identified that there was no observable documentation being consistently retained to indicate that a review of the cash draws was being performed prior to submission. Cause ? Reviews surrounding the preparation and draws of federal funds prior to submission were not properly documented and retained by the Organization. Effect - Without proper documentation, it is difficult to determine that a secondary review of the cash draws occurred. This could result in Organization drawing funds in inappropriate amounts or for unallowed costs. Questioned Costs - None reported Context/Sampling - A sample of eight cash draws out of a population of twenty-four were selected. Four of the eight cash draws selected for testing did not have evidence of review. of the items in the sample showed evidence of review. Repeat Finding from Prior Year ? Yes, Finding 2021-003 Recommendation - We recommend that a member of the Organization?s staff who does not prepare the cash draw review the cash draw prior to submission and document that review. The documentation of the review should be retained. Views of Responsible Officials - Management agrees with the finding.
2022-004 U.S. Department of Justice Federal Financial Assistance Listing #16.575 Victims of Crime Act (VOCA) Procurement, Suspension and Debarment Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria - Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) Sections 200.318 through 200.326 set forth the procurement standards non-federal entities other than states must follow when operating federal programs and the procurement procedures required depending on the dollar amount of the transaction. Condition - During the course of our engagement, we identified that there was no observable documentation to indicate that the required procurement procedures were performed on vendors. Cause - Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and all applicable CFR sections and controls were not adequately designed to ensure compliance with all of these requirements. Effect - A lack of established controls increases the overall risk that the Organization is contracting and awarding contracts which may not be the most cost advantageous. Questioned Costs - None reported Context/Sampling - A sample of 9 expenditures out of a population of 12 expenditures were selected for testing. Four of these met the conditions of the procurement policy (i.e., non- payroll related expenditures) and did not have the supporting documentation retained due to having entered into the contract during 2020 or prior to the implementation of the procurement policy in 2020. Two of these met the conditions of the procurement policy (i.e., non-payroll related expenditures) and did not go through the Organization?s procurement policy. Repeat Finding from Prior Year ? Yes, Finding 2021-004 Recommendation - We recommend that the Organization maintain the appropriate documentation evidencing that procurement procedures have been completed. Views of Responsible Officials - Management agrees with the finding.
2022-005 U.S. Department of Justice Federal Financial Assistance Listing #16.575 Victims of Crime Act (VOCA) Activities Allowed or Unallowed and Allowable Costs/Cost Principles Significant Deficiency in Internal Control over Compliance Criteria - The Organization allocates various expenditures to several grants, generally using a predetermined percentage split. However, the Organization does have some ability to change the allocation given specific facts and circumstances. Condition - During the course of our engagement, we noted instances where the allocation did not follow the predetermined percentage split, but the allocation methodology and the reason for the allocation not following the predetermine percentage split was not documented. Cause - The grant does allow for changes to the allocation of certain expenditures. However, management was not documenting the reasons for the different allocation methods being used if the predetermine percentage split was not being followed. Effect - Without proper documentation, it is difficult to determine that a reasonable allocation of expenditures occurred. This could result in the granting agencies questioning the allocations and management may not be able to reproduce the methodology or explain the allocation methodology being used. Questioned Costs - None reported Context/Sampling - A sample of 60 expenditures out of over 1,100 expenditures were selected for testing. Ten allocations did not follow the predetermined percentage split and had limited documentation as to the allocation methodology being used. Repeat Finding from Prior Year ? Yes, 2021-005 Recommendation - We recommend that the Organization document the allocation methodology being used for expenditures that relate to more than one grant, especially in cases where the predetermined allocation percentage is not being used. Views of Responsible Officials - Management agrees with the finding.
2022-003 U.S. Department of Justice Federal Financial Assistance Listing #16.575 Victims of Crime Act (VOCA) Cash Management Significant Deficiency in Internal Control over Compliance Criteria - A good system of internal control over compliance related to a program?s cash management policies should require a review of the cash draw by a second individual and documentation of the review should be properly retained by the Organization. Condition - During the course of our engagement, we identified that there was no observable documentation being consistently retained to indicate that a review of the cash draws was being performed prior to submission. Cause ? Reviews surrounding the preparation and draws of federal funds prior to submission were not properly documented and retained by the Organization. Effect - Without proper documentation, it is difficult to determine that a secondary review of the cash draws occurred. This could result in Organization drawing funds in inappropriate amounts or for unallowed costs. Questioned Costs - None reported Context/Sampling - A sample of eight cash draws out of a population of twenty-four were selected. Four of the eight cash draws selected for testing did not have evidence of review. of the items in the sample showed evidence of review. Repeat Finding from Prior Year ? Yes, Finding 2021-003 Recommendation - We recommend that a member of the Organization?s staff who does not prepare the cash draw review the cash draw prior to submission and document that review. The documentation of the review should be retained. Views of Responsible Officials - Management agrees with the finding.
2022-004 U.S. Department of Justice Federal Financial Assistance Listing #16.575 Victims of Crime Act (VOCA) Procurement, Suspension and Debarment Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria - Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) Sections 200.318 through 200.326 set forth the procurement standards non-federal entities other than states must follow when operating federal programs and the procurement procedures required depending on the dollar amount of the transaction. Condition - During the course of our engagement, we identified that there was no observable documentation to indicate that the required procurement procedures were performed on vendors. Cause - Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and all applicable CFR sections and controls were not adequately designed to ensure compliance with all of these requirements. Effect - A lack of established controls increases the overall risk that the Organization is contracting and awarding contracts which may not be the most cost advantageous. Questioned Costs - None reported Context/Sampling - A sample of 9 expenditures out of a population of 12 expenditures were selected for testing. Four of these met the conditions of the procurement policy (i.e., non- payroll related expenditures) and did not have the supporting documentation retained due to having entered into the contract during 2020 or prior to the implementation of the procurement policy in 2020. Two of these met the conditions of the procurement policy (i.e., non-payroll related expenditures) and did not go through the Organization?s procurement policy. Repeat Finding from Prior Year ? Yes, Finding 2021-004 Recommendation - We recommend that the Organization maintain the appropriate documentation evidencing that procurement procedures have been completed. Views of Responsible Officials - Management agrees with the finding.
2022-005 U.S. Department of Justice Federal Financial Assistance Listing #16.575 Victims of Crime Act (VOCA) Activities Allowed or Unallowed and Allowable Costs/Cost Principles Significant Deficiency in Internal Control over Compliance Criteria - The Organization allocates various expenditures to several grants, generally using a predetermined percentage split. However, the Organization does have some ability to change the allocation given specific facts and circumstances. Condition - During the course of our engagement, we noted instances where the allocation did not follow the predetermined percentage split, but the allocation methodology and the reason for the allocation not following the predetermine percentage split was not documented. Cause - The grant does allow for changes to the allocation of certain expenditures. However, management was not documenting the reasons for the different allocation methods being used if the predetermine percentage split was not being followed. Effect - Without proper documentation, it is difficult to determine that a reasonable allocation of expenditures occurred. This could result in the granting agencies questioning the allocations and management may not be able to reproduce the methodology or explain the allocation methodology being used. Questioned Costs - None reported Context/Sampling - A sample of 60 expenditures out of over 1,100 expenditures were selected for testing. Ten allocations did not follow the predetermined percentage split and had limited documentation as to the allocation methodology being used. Repeat Finding from Prior Year ? Yes, 2021-005 Recommendation - We recommend that the Organization document the allocation methodology being used for expenditures that relate to more than one grant, especially in cases where the predetermined allocation percentage is not being used. Views of Responsible Officials - Management agrees with the finding.