Audit 298546

Finding 2023-002: Period of Performance Information on the Federal Program: 93.368 Criteria: 2 CFR §200.309 non-Federal entity may charge to the Federal award only allowable costs incurred during the period of performance (except as described in §200.461 Publication and printing costs) and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award that were authorized by the Federal awarding agency or pass-through entity. Condition: In testing the Foundation's compliance with the period of performance availability for Federal awards, we noted one instance in which an invoice for an expense incurred outside of both the award's period of performance and the Foundation's fiscal year-end was recorded and charged to the Federal award. Cause: The Foundation's controls are not adequately designed to detect an expense recorded outside of the award's period of performance or outside of the Foundation's fiscal year-end. Effect: Costs that are not incurred and recorded within the period of performance may be determined and considered an unallowable charge against a Federally funded program. Questioned Costs: $55,000 Context: Our audit procedures consisted of testwork completed on individual expenditures charged to the Federal awards that ended within the 2023 fiscal year-end. The report in which samples were selected was generated directly from the Foundation's general ledger (accounting system). We consider our sample to be representative of the population. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that all invoices be reviewed to ensure that expenses are appropriately recorded in the period for which they are incurred.

Finding 2023-003: Non-Compliance with Suspension and Debarment Information on the Federal Program: 93.368 Criteria: 2 CFR §200.213 non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Condition: We noted that while the Foundation does conduct screenings on all vendors, suppliers and consultants, the date that the screening is conducted is not documented. As such, we are unable to determine if the screening was conducted prior to payment or signing of the contract. Cause: The Foundation does not require that the date the screening is conducted be documented. Effect: Failure to screen potential and current vendors, suppliers or contractors prior to payment or contract signing increases the potential that Federal funds be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: Our audit procedures consisted of testwork completed on individual expenditures charged to the Federal awards. The report in which samples were selected was generated directly from the Foundation's general ledger (accounting system). We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that the Foundation revise their policy regarding suspension and debarment to require that all screenings are accompanied by the documented date in which they were conducted.

Finding 2023-002: Period of Performance Information on the Federal Program: 93.368 Criteria: 2 CFR §200.309 non-Federal entity may charge to the Federal award only allowable costs incurred during the period of performance (except as described in §200.461 Publication and printing costs) and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award that were authorized by the Federal awarding agency or pass-through entity. Condition: In testing the Foundation's compliance with the period of performance availability for Federal awards, we noted one instance in which an invoice for an expense incurred outside of both the award's period of performance and the Foundation's fiscal year-end was recorded and charged to the Federal award. Cause: The Foundation's controls are not adequately designed to detect an expense recorded outside of the award's period of performance or outside of the Foundation's fiscal year-end. Effect: Costs that are not incurred and recorded within the period of performance may be determined and considered an unallowable charge against a Federally funded program. Questioned Costs: $55,000 Context: Our audit procedures consisted of testwork completed on individual expenditures charged to the Federal awards that ended within the 2023 fiscal year-end. The report in which samples were selected was generated directly from the Foundation's general ledger (accounting system). We consider our sample to be representative of the population. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that all invoices be reviewed to ensure that expenses are appropriately recorded in the period for which they are incurred.

Finding 2023-003: Non-Compliance with Suspension and Debarment Information on the Federal Program: 93.368 Criteria: 2 CFR §200.213 non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Condition: We noted that while the Foundation does conduct screenings on all vendors, suppliers and consultants, the date that the screening is conducted is not documented. As such, we are unable to determine if the screening was conducted prior to payment or signing of the contract. Cause: The Foundation does not require that the date the screening is conducted be documented. Effect: Failure to screen potential and current vendors, suppliers or contractors prior to payment or contract signing increases the potential that Federal funds be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: Our audit procedures consisted of testwork completed on individual expenditures charged to the Federal awards. The report in which samples were selected was generated directly from the Foundation's general ledger (accounting system). We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that the Foundation revise their policy regarding suspension and debarment to require that all screenings are accompanied by the documented date in which they were conducted.