Criteria: An entity should have adequate controls in place to ensure that costs included in federal grant reimbursement
requests are allowable under the terms of the award.
Condition and Context: During our review of allowable costs for the year ended June 30, 2023, we noted certain capital
expenditures that were not approved in writing by the federal awarding agency or the pass-through entity as required by the cost principles outlined in 2 CFR 200.439.
Questioned Costs: $26,566
Cause: Management oversight
Effect: The Organization may receive reimbursements through federal programs for which it is not entitled.
Repeat Finding: No
Recommendation: Reinforce controls to ensure all project invoices including capital expenditures are reviewed and that only eligible costs are reported under the federal award, or that prior authorization by the federal awarding agency or
pass-through entity is obtained when required.
Views of Management: Management agrees with the finding and is implementing procedures that are further discussed in
the corrective action plan. See Corrective Action Plan.
Criteria: All grantees that expend federal funds must comply with the procurement guidelines found in 2 CFR 200.318-.327
and use documented procurement procedures that are consistent with the applicable laws and regulations for the acquisition of property or services required under a Federal award or subaward.
Condition and Context: The Organization developed a procurement policy during the year ended June 30, 2023 in response
to prior audit findings; however, the policy does not include complete and current procurement procedures that fully align
with the requirements of section 2 CFR 200.318-.327. The Organization’s program expenditures for the year ended June 30, 2023 did not include purchases in excess of the Simplified Acquisition Threshold and thus informal procurement procedures were acceptable.
Questioned Costs: None
Cause: Management oversight
Effect: Without a documented procurement policy that aligns with the requirements of 2 CFR 200.318-.327, purchases may
be made under the federal program that do not comply with the relevant procurement standards established by 2 CFR 200.
Repeat Finding: Yes; 2022-004
Recommendation: Management should revise its procurement policy to include current language and the required elements of 2 CFR 200.318-.327.
Views of Management: Management agrees with the finding and is implementing procedures that are further discussed in
the corrective action plan. See Corrective Action Plan.
Criteria: All grantees that expend federal funds must comply with the procurement guidelines found in 2 CFR 200.318-.327
and use documented procurement procedures that are consistent with the applicable laws and regulations for the acquisition of property or services required under a Federal award or subaward.
Condition and Context: The Organization developed a procurement policy during the year ended June 30, 2023 in response
to prior audit findings; however, the policy does not include complete and current procurement procedures that fully align
with the requirements of section 2 CFR 200.318-.327. The Organization’s program expenditures for the year ended June 30, 2023 did not include purchases in excess of the Simplified Acquisition Threshold and thus informal procurement procedures were acceptable.
Questioned Costs: None
Cause: Management oversight
Effect: Without a documented procurement policy that aligns with the requirements of 2 CFR 200.318-.327, purchases may
be made under the federal program that do not comply with the relevant procurement standards established by 2 CFR 200.
Repeat Finding: Yes; 2022-004
Recommendation: Management should revise its procurement policy to include current language and the required elements of 2 CFR 200.318-.327.
Views of Management: Management agrees with the finding and is implementing procedures that are further discussed in
the corrective action plan. See Corrective Action Plan.
Criteria: All grantees that expend federal funds must comply with the procurement guidelines found in 2 CFR 200.318-.327
and use documented procurement procedures that are consistent with the applicable laws and regulations for the acquisition of property or services required under a Federal award or subaward.
Condition and Context: The Organization developed a procurement policy during the year ended June 30, 2023 in response
to prior audit findings; however, the policy does not include complete and current procurement procedures that fully align
with the requirements of section 2 CFR 200.318-.327. The Organization’s program expenditures for the year ended June 30, 2023 did not include purchases in excess of the Simplified Acquisition Threshold and thus informal procurement procedures were acceptable.
Questioned Costs: None
Cause: Management oversight
Effect: Without a documented procurement policy that aligns with the requirements of 2 CFR 200.318-.327, purchases may
be made under the federal program that do not comply with the relevant procurement standards established by 2 CFR 200.
Repeat Finding: Yes; 2022-004
Recommendation: Management should revise its procurement policy to include current language and the required elements of 2 CFR 200.318-.327.
Views of Management: Management agrees with the finding and is implementing procedures that are further discussed in
the corrective action plan. See Corrective Action Plan.
Criteria: The Organization’s contract for the federal award includes periodic performance reporting requirements that are
due on certain dates following the reporting period-end.
Condition and Context: We noted that the performance reports specified by the grant agreement were not prepared and filed in a timely manner.
Questioned Costs: None
Cause: Management oversight
Effect: Without adequate controls over these filings requirement, the Organization may not be in compliance with the terms of the grant agreement.
Repeat Finding: No
Recommendation: Prepare and file the delinquent performance reports with the pass-through entity as soon as possible.
Views of Management: Management agrees with the finding and is implementing procedures that are further discussed in
the corrective action plan. See Corrective Action Plan.
Criteria: The Organization’s contract for the federal award includes periodic performance reporting requirements that are
due on certain dates following the reporting period-end.
Condition and Context: We noted that the performance reports specified by the grant agreement were not prepared and filed in a timely manner.
Questioned Costs: None
Cause: Management oversight
Effect: Without adequate controls over these filings requirement, the Organization may not be in compliance with the terms of the grant agreement.
Repeat Finding: No
Recommendation: Prepare and file the delinquent performance reports with the pass-through entity as soon as possible.
Views of Management: Management agrees with the finding and is implementing procedures that are further discussed in
the corrective action plan. See Corrective Action Plan.
Criteria: An entity should have adequate controls in place to ensure that costs included in federal grant reimbursement
requests are allowable under the terms of the award.
Condition and Context: During our review of allowable costs for the year ended June 30, 2023, we noted certain capital
expenditures that were not approved in writing by the federal awarding agency or the pass-through entity as required by the cost principles outlined in 2 CFR 200.439.
Questioned Costs: $26,566
Cause: Management oversight
Effect: The Organization may receive reimbursements through federal programs for which it is not entitled.
Repeat Finding: No
Recommendation: Reinforce controls to ensure all project invoices including capital expenditures are reviewed and that only eligible costs are reported under the federal award, or that prior authorization by the federal awarding agency or
pass-through entity is obtained when required.
Views of Management: Management agrees with the finding and is implementing procedures that are further discussed in
the corrective action plan. See Corrective Action Plan.
Criteria: All grantees that expend federal funds must comply with the procurement guidelines found in 2 CFR 200.318-.327
and use documented procurement procedures that are consistent with the applicable laws and regulations for the acquisition of property or services required under a Federal award or subaward.
Condition and Context: The Organization developed a procurement policy during the year ended June 30, 2023 in response
to prior audit findings; however, the policy does not include complete and current procurement procedures that fully align
with the requirements of section 2 CFR 200.318-.327. The Organization’s program expenditures for the year ended June 30, 2023 did not include purchases in excess of the Simplified Acquisition Threshold and thus informal procurement procedures were acceptable.
Questioned Costs: None
Cause: Management oversight
Effect: Without a documented procurement policy that aligns with the requirements of 2 CFR 200.318-.327, purchases may
be made under the federal program that do not comply with the relevant procurement standards established by 2 CFR 200.
Repeat Finding: Yes; 2022-004
Recommendation: Management should revise its procurement policy to include current language and the required elements of 2 CFR 200.318-.327.
Views of Management: Management agrees with the finding and is implementing procedures that are further discussed in
the corrective action plan. See Corrective Action Plan.
Criteria: All grantees that expend federal funds must comply with the procurement guidelines found in 2 CFR 200.318-.327
and use documented procurement procedures that are consistent with the applicable laws and regulations for the acquisition of property or services required under a Federal award or subaward.
Condition and Context: The Organization developed a procurement policy during the year ended June 30, 2023 in response
to prior audit findings; however, the policy does not include complete and current procurement procedures that fully align
with the requirements of section 2 CFR 200.318-.327. The Organization’s program expenditures for the year ended June 30, 2023 did not include purchases in excess of the Simplified Acquisition Threshold and thus informal procurement procedures were acceptable.
Questioned Costs: None
Cause: Management oversight
Effect: Without a documented procurement policy that aligns with the requirements of 2 CFR 200.318-.327, purchases may
be made under the federal program that do not comply with the relevant procurement standards established by 2 CFR 200.
Repeat Finding: Yes; 2022-004
Recommendation: Management should revise its procurement policy to include current language and the required elements of 2 CFR 200.318-.327.
Views of Management: Management agrees with the finding and is implementing procedures that are further discussed in
the corrective action plan. See Corrective Action Plan.
Criteria: All grantees that expend federal funds must comply with the procurement guidelines found in 2 CFR 200.318-.327
and use documented procurement procedures that are consistent with the applicable laws and regulations for the acquisition of property or services required under a Federal award or subaward.
Condition and Context: The Organization developed a procurement policy during the year ended June 30, 2023 in response
to prior audit findings; however, the policy does not include complete and current procurement procedures that fully align
with the requirements of section 2 CFR 200.318-.327. The Organization’s program expenditures for the year ended June 30, 2023 did not include purchases in excess of the Simplified Acquisition Threshold and thus informal procurement procedures were acceptable.
Questioned Costs: None
Cause: Management oversight
Effect: Without a documented procurement policy that aligns with the requirements of 2 CFR 200.318-.327, purchases may
be made under the federal program that do not comply with the relevant procurement standards established by 2 CFR 200.
Repeat Finding: Yes; 2022-004
Recommendation: Management should revise its procurement policy to include current language and the required elements of 2 CFR 200.318-.327.
Views of Management: Management agrees with the finding and is implementing procedures that are further discussed in
the corrective action plan. See Corrective Action Plan.
Criteria: The Organization’s contract for the federal award includes periodic performance reporting requirements that are
due on certain dates following the reporting period-end.
Condition and Context: We noted that the performance reports specified by the grant agreement were not prepared and filed in a timely manner.
Questioned Costs: None
Cause: Management oversight
Effect: Without adequate controls over these filings requirement, the Organization may not be in compliance with the terms of the grant agreement.
Repeat Finding: No
Recommendation: Prepare and file the delinquent performance reports with the pass-through entity as soon as possible.
Views of Management: Management agrees with the finding and is implementing procedures that are further discussed in
the corrective action plan. See Corrective Action Plan.
Criteria: The Organization’s contract for the federal award includes periodic performance reporting requirements that are
due on certain dates following the reporting period-end.
Condition and Context: We noted that the performance reports specified by the grant agreement were not prepared and filed in a timely manner.
Questioned Costs: None
Cause: Management oversight
Effect: Without adequate controls over these filings requirement, the Organization may not be in compliance with the terms of the grant agreement.
Repeat Finding: No
Recommendation: Prepare and file the delinquent performance reports with the pass-through entity as soon as possible.
Views of Management: Management agrees with the finding and is implementing procedures that are further discussed in
the corrective action plan. See Corrective Action Plan.