Audit 295841

FY End
2023-06-30
Total Expended
$3.86M
Findings
10
Programs
1
Organization: Epilepsy Foundation of America (MD)
Year: 2023 Accepted: 2024-03-19

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
381087 2023-002 Material Weakness - P
381088 2023-003 Material Weakness - I
381089 2023-004 Material Weakness Yes C
381090 2023-005 Significant Deficiency - B
381091 2023-006 Significant Deficiency Yes L
957529 2023-002 Material Weakness - P
957530 2023-003 Material Weakness - I
957531 2023-004 Material Weakness Yes C
957532 2023-005 Significant Deficiency - B
957533 2023-006 Significant Deficiency Yes L

Programs

ALN Program Spent Major Findings
93.850 Improving Epilepsy Programs, Services, and Outcomes Through National Partnerships $3.86M Yes 5

Contacts

Name Title Type
SPY7BAJM1AN9 Rahel Rosner Auditee
3019183704 Lisa Johnson Auditor
No contacts on file

Notes to SEFA

Title: Basis of Presentation 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. De Minimis Rate Used: N Rate Explanation: The Foundation has elected not to use the 10% de minimis indirect cost rate allowed under the Uniform Guidance. The accompanying schedule of expenditures of federal awards (the Schedule) includes the federal grant activity of the Epilepsy Foundation of America, DBA Epilepsy Foundation (the “Foundation”) under programs of the federal government for the year ended June 30, 2023. The information in this Schedule is presented in accordance with requirements of Title 2 U.S. Code of Federal Regulations (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 Foundation, it is not intended to and does not present the financial position, changes in net assets, or cash flows of the Foundation.
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. De Minimis Rate Used: N Rate Explanation: The Foundation has elected not to use the 10% de minimis indirect cost rate allowed under the Uniform Guidance. 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.
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. De Minimis Rate Used: N Rate Explanation: The Foundation has elected not to use the 10% de minimis indirect cost rate allowed under the Uniform Guidance. The Foundation has elected not to use the 10% de minimis indirect cost rate allowed under the Uniform Guidance.

Finding Details

Condition: Our examination of the Foundation’s Schedule of Expenditures of Federal Awards (SEFA) found various errors that resulted in adjustments to both direct and indirect grant revenue. We received several iterations of the SEFA and adjustments had to be made to each version before a complete SEFA was received that reconciled to the general ledger. Criteria: The SEFA is used to determine the amount expended for federal grants that is reported to the government. Cause: There is a lack of established procedures for preparing and reviewing the SEFA. Effect: Multiple iterations of the SEFA were received and adjustments had to be made to each version causing a delay in finalizing our single audit procedures. Recommendation: We recommend management implement procedures to prepare an accurate SEFA and a second layer of review is performed before the SEFA is finalized to identify any inaccuracies or inconsistencies with the general ledger. Views of Responsible Officials and Planned Corrective Actions: The Foundation is strictly enforcing a policy that AMEX receipts from staff are due three days after the statement is posted to ensure all expenditure information is received and recorded timely for purposes of inclusion in the SEFA.
Condition: A sample of three (3) contractors were selected for testing procurement, suspension, and debarment. Our test work indicated that there was no documentation for the verification of suspension and debarment for all three contractors selected for testing. Criteria: Suspension and debarment regulations under 2 CFR should be followed. Cause: Procedures have not been established to verify if vendors contracted with the Foundation related to the federal program in excess of $25,000 are not suspended, debarred or otherwise excluded from doing business. Effect: Noncompliance with the federal award program’s suspension and debarment compliance requirements could occur and not be detected and corrected timely. Recommendation: We recommend that the Foundation establish and document suspension and debarment reviews for all contracts entered into using federal awards. Views of Responsible Officials and Planned Corrective Actions: The Foundation has always had procedures in place to research whether an organization is suspended and debarred. The Foundation has also developed a process by which the grant administration team both looks up and takes screen shots of the search for each vendor’s status in the database (both upon contract renewal or when entering a new contract with a value of more than $25,000). This information is maintained by the grant administration team.
Condition: A sample of four (4) drawdowns were selected for testing cash management procedures. Our test work found that the Foundation could not produce adequate documentation of the expenses supporting each drawdown request and the drawdown requests did not have documented approvals. Additionally, we found that there is no process in place to prevent entries from being recorded in the accounting ledger once a period has been closed. In reviewing the federal drawdowns made during the year, we determined that the Foundation rounded drawdowns to the nearest hundred dollar. As a result of our review of the federal grants receivable general ledger, we also found that the Foundation erroneously failed to drawdown $76,235 of federal funds related to FY23 expenditures incurred. We notified management of this matter and the amount was subsequently drawn down. Criteria: The Uniform Guidance requires organizations who receive funds on a cost reimbursement basis to draw down funds based on allowable expenditures under the grant. Cause: Overall lack of policies and procedures regarding retention of drawdown documentation and approval of drawdowns. Effect: Reports showing expenses for drawdowns were run real-time and were not maintained. Accounting records are not closed at each period end, which allows for erroneous journal entries to be made. Based on our tests performed over federal expenditures, we found no unallowable costs included in the drawdown request. Additionally, there was an outstanding receivable at the end of FY23, which was drawn down subsequent to year end. Recommendation: We recommend that the Foundation save all supporting schedules used to calculate each drawdown. We also recommend that the Foundation drawdown federal funds in an amount equal to the exact expenses incurred during the period and the drawdowns are approved. Furthermore, we recommend that only the accounting team have ability to affect the accounting records. Lastly, we recommend that the Foundation reconcile and review the grants receivable balance monthly to ensure all drawdowns occur on a timely basis. Views of Responsible Officials and Planned Corrective Actions: The Foundation is strictly enforcing a policy that AMEX receipts from staff are due three days after the statement is posted. With this clear policy in place, the period end is accurate with drawdowns reflecting the activity incurred in that period. All supporting schedules are being saved.
Condition: A sample of forty (40) payroll transactions were selected for testing, spanning across five (5) months. For one month selected, the Foundation was unable to provide key payroll reports to reconcile payroll to the amount charged to the federal program. Criteria: The Uniform Guidance requires organizations to establish internal controls to detect potential noncompliance. Cause: Overall lack of policies and procedures regarding retention of documentation. Management believes the payroll report was overwritten by a subsequent month. Effect: Noncompliance with the federal award program’s allowance costs compliance requirements could occur and not be detected and corrected timely. Recommendation: We recommend that the Foundation establish procedures to back up all pertinent payroll reports to a secure location to prevent loss of data. Views of Responsible Officials and Planned Corrective Actions: A previous staff member (who is no longer with the Foundation) appears to have erroneously overwritten a payroll report. We now have a process where each month, a payroll folder is created with the correct reports and supporting documents. Once again, this process is in place with documentation. As part of our collation process, these will be gathered into a procedural manual.
Condition: Our testwork over the reporting compliance requirement included a sample of annual and quarterly financial and performance reports. We noted that the reports did not have a documented review of the reports prior to submission. Criteria: The Uniform Guidance requires organizations to establish internal controls to detect potential noncompliance. Cause: Overall lack of policies and procedures regarding retention of review documentation. Effect: Non-compliance with adequate review over required financial and program reports. Recommendation: We recommend that management establish procedures to document the review and approval of the required financial and performance reports. Views of Responsible Officials and Planned Corrective Actions: The reports to the CDC are provided in quarterly meetings. We were able to provide these reports to the Auditors and are now receiving these reports from the program office so that they can be maintained in a file which can be used for audit purposes.
Condition: Our examination of the Foundation’s Schedule of Expenditures of Federal Awards (SEFA) found various errors that resulted in adjustments to both direct and indirect grant revenue. We received several iterations of the SEFA and adjustments had to be made to each version before a complete SEFA was received that reconciled to the general ledger. Criteria: The SEFA is used to determine the amount expended for federal grants that is reported to the government. Cause: There is a lack of established procedures for preparing and reviewing the SEFA. Effect: Multiple iterations of the SEFA were received and adjustments had to be made to each version causing a delay in finalizing our single audit procedures. Recommendation: We recommend management implement procedures to prepare an accurate SEFA and a second layer of review is performed before the SEFA is finalized to identify any inaccuracies or inconsistencies with the general ledger. Views of Responsible Officials and Planned Corrective Actions: The Foundation is strictly enforcing a policy that AMEX receipts from staff are due three days after the statement is posted to ensure all expenditure information is received and recorded timely for purposes of inclusion in the SEFA.
Condition: A sample of three (3) contractors were selected for testing procurement, suspension, and debarment. Our test work indicated that there was no documentation for the verification of suspension and debarment for all three contractors selected for testing. Criteria: Suspension and debarment regulations under 2 CFR should be followed. Cause: Procedures have not been established to verify if vendors contracted with the Foundation related to the federal program in excess of $25,000 are not suspended, debarred or otherwise excluded from doing business. Effect: Noncompliance with the federal award program’s suspension and debarment compliance requirements could occur and not be detected and corrected timely. Recommendation: We recommend that the Foundation establish and document suspension and debarment reviews for all contracts entered into using federal awards. Views of Responsible Officials and Planned Corrective Actions: The Foundation has always had procedures in place to research whether an organization is suspended and debarred. The Foundation has also developed a process by which the grant administration team both looks up and takes screen shots of the search for each vendor’s status in the database (both upon contract renewal or when entering a new contract with a value of more than $25,000). This information is maintained by the grant administration team.
Condition: A sample of four (4) drawdowns were selected for testing cash management procedures. Our test work found that the Foundation could not produce adequate documentation of the expenses supporting each drawdown request and the drawdown requests did not have documented approvals. Additionally, we found that there is no process in place to prevent entries from being recorded in the accounting ledger once a period has been closed. In reviewing the federal drawdowns made during the year, we determined that the Foundation rounded drawdowns to the nearest hundred dollar. As a result of our review of the federal grants receivable general ledger, we also found that the Foundation erroneously failed to drawdown $76,235 of federal funds related to FY23 expenditures incurred. We notified management of this matter and the amount was subsequently drawn down. Criteria: The Uniform Guidance requires organizations who receive funds on a cost reimbursement basis to draw down funds based on allowable expenditures under the grant. Cause: Overall lack of policies and procedures regarding retention of drawdown documentation and approval of drawdowns. Effect: Reports showing expenses for drawdowns were run real-time and were not maintained. Accounting records are not closed at each period end, which allows for erroneous journal entries to be made. Based on our tests performed over federal expenditures, we found no unallowable costs included in the drawdown request. Additionally, there was an outstanding receivable at the end of FY23, which was drawn down subsequent to year end. Recommendation: We recommend that the Foundation save all supporting schedules used to calculate each drawdown. We also recommend that the Foundation drawdown federal funds in an amount equal to the exact expenses incurred during the period and the drawdowns are approved. Furthermore, we recommend that only the accounting team have ability to affect the accounting records. Lastly, we recommend that the Foundation reconcile and review the grants receivable balance monthly to ensure all drawdowns occur on a timely basis. Views of Responsible Officials and Planned Corrective Actions: The Foundation is strictly enforcing a policy that AMEX receipts from staff are due three days after the statement is posted. With this clear policy in place, the period end is accurate with drawdowns reflecting the activity incurred in that period. All supporting schedules are being saved.
Condition: A sample of forty (40) payroll transactions were selected for testing, spanning across five (5) months. For one month selected, the Foundation was unable to provide key payroll reports to reconcile payroll to the amount charged to the federal program. Criteria: The Uniform Guidance requires organizations to establish internal controls to detect potential noncompliance. Cause: Overall lack of policies and procedures regarding retention of documentation. Management believes the payroll report was overwritten by a subsequent month. Effect: Noncompliance with the federal award program’s allowance costs compliance requirements could occur and not be detected and corrected timely. Recommendation: We recommend that the Foundation establish procedures to back up all pertinent payroll reports to a secure location to prevent loss of data. Views of Responsible Officials and Planned Corrective Actions: A previous staff member (who is no longer with the Foundation) appears to have erroneously overwritten a payroll report. We now have a process where each month, a payroll folder is created with the correct reports and supporting documents. Once again, this process is in place with documentation. As part of our collation process, these will be gathered into a procedural manual.
Condition: Our testwork over the reporting compliance requirement included a sample of annual and quarterly financial and performance reports. We noted that the reports did not have a documented review of the reports prior to submission. Criteria: The Uniform Guidance requires organizations to establish internal controls to detect potential noncompliance. Cause: Overall lack of policies and procedures regarding retention of review documentation. Effect: Non-compliance with adequate review over required financial and program reports. Recommendation: We recommend that management establish procedures to document the review and approval of the required financial and performance reports. Views of Responsible Officials and Planned Corrective Actions: The reports to the CDC are provided in quarterly meetings. We were able to provide these reports to the Auditors and are now receiving these reports from the program office so that they can be maintained in a file which can be used for audit purposes.