Ref 2023-003: Classification, completeness and accuracy of bank accounts (significant
deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23
Pass-through: All applicable
Criteria:
Accurate and reliable financial records, including listing of bank accounts and bank reconciliations,
are necessary to ensure that testing populations are complete, accurate and bank accounts are
correctly classified.
Condition:
Plan Inc. holds over 550 bank accounts between Global Hub, Plan Ltd and the Country Offices. The
following points were noted during the Plan Inc. financial statement audit:
1. From our testing performed over opening and closing bank accounts at the regional hub level, we
noted an account which was classified as closed prior to receiving a formal letter from the bank
confirming the closure. The account remains open with a balance of €36.
2. In the bank confirmation we independently received from ECO Bank Cameroon we noted two
additional bank account balances of €212k (immaterial and below de minimis reporting threshold)
which were not included in the general ledger.
3. During our testing, differences in bank account numbers were noted in several instances between
either bank confirmations / bank statements / bank reconciliations compared to the bank account
listing which reflected the old account numbers. This was the case for accounts at five banks across
different Country Offices (‘CO’).
4. During our testing, differences in bank account numbers were noted from three bank
reconciliations (GL180090, GL180080, and GL168060) compared to the bank account listing as a
result of typos made on the bank reconciliations. The account numbers per Plan Inc. bank account
listing for these accounts, however, was correct.
5. During our testing, it was noted that two bank reconciliations (GL168010 and GL168110) had
incorrect local currencies input into the bank reconciliation in the currency field. This had no financial
impact on the bank reconciliations performed.
6. For two GL accounts (GL168120 and GL168129) differences amounting to €693,984 between the
denominated balance in bank reconciliation and the denominated balance per trial balance were
noted. Plan confirmed the amount pertains to the revaluation of currency and that the account should
not be reevaluated in local currency. This is a system error due to the wrong set up of the monthly
revaluation process for these two specific GL accounts.
Cause:
For the first point, Plan had acted on the request to close the bank account when the request had been
acknowledged but before it had been confirmed, and therefore removed the account from the cash
listing despite a formal confirmation letter from the bank not being received.
For the second, the root cause of this issue is the CO not following the process in relation to opening
bank accounts and appropriately informing Regional Hub (‘RH’) and Global Hub (‘GH’).
For points three and four, the revised bank account numbers were not updated on the bank account
listing which still contained the old account numbers; and for point five the CO had not picked up the
incorrect currency field noted or incorrect bank account number following review of the
reconciliation.
For the sixth point, two GL accounts had an incorrect variant set up causing differences between the
bank reconciliation and the trial balance.
Effect:
Classifying balances as closed creates risks over the completeness of the bank account listing. There is
a risk that a large number of accounts are classified as closed despite still being open or an account
with a material cash balance could be excluded from the cash listing.
Not identifying and reporting bank accounts on a timely basis to GH and bank account numbers
inaccurately reflected on the bank account listing or bank reconciliations creates risks over the
completeness of the bank account listing.
Per the Bank Secrecy Act, Plan is required through FBAR ( Foreign Bank and Financial Accounts, US
Federal Government) to report all non-US bank accounts to the US in March each year. FBAR then
performs ad hoc checks of various entities and if Plan is found not reporting a full list of active
accounts, they will receive penalty fines for not complying with US requirements.
Incorrect currencies or account numbers reflected on the bank reconciliations and bank fees not
included creates risk over the completeness and accuracy of bank reconciliations.
Additionally, the incorrect application of the variants creates the risk of inaccuracies performed on the
foreign currency translation of bank accounts.
Recommendation:
We recommend the following:
Bank accounts are not classified as closed until a formal closure letter from the bank is received.
The RHs perform timely monthly reviews to ensure the completeness of bank accounts and COs are
reminded of the process around opening and closing bank accounts and the required notifications to
RH and GH.
Management put in place a process whereby appropriate review of bank details is performed at a CO
level during the year end FBAR process as reliance is placed by GH on what is reported by the Country
Offices.
Management update the bank account listing to reflect updated bank account numbers.
Management ensure COs review the bank reconciliations for accuracy of financial and non-financial
data (such as account numbers).
Management ensure the correct set up of the monthly revaluation process for bank related GL
accounts.
Views of Responsible Officials and Management’s Corrective Action Plan :
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-004: Foreign exchange translation methodology (repeat of prior year finding 2022-004, 2021-005, 2020-006, 2019-006) (significant deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23, FY22, FY21, FY20 and FY19
Pass-through: All applicable
Criteria:
Accurate and reliable financial records of many kinds are necessary to meet ongoing financial
reporting and operational needs and requirements. The rate of exchange used throughout any given
month is the spot rate from the second to last working day of the prior month. This is not therefore the
‘the rate of exchange ruling at the date of the transaction’ in accordance with the Plan Inc. accounting
policies as stated in the financial statements.
Condition:
For all transactions, the impact of exchange rates takes place in the following stages:
At a transaction level
1. Translation from document currency (i.e. currency of income/expense per invoice) to local
currency at the time of initial recognition
2. Local currency to functional currency (Euro)
3. Translation to actual rate at date of settlement
4. Translation of outstanding amounts within the balance sheet at the period end rate
At the consolidation level
5. Functional currency to reporting currency (USD)
We note the following:
The monthly rate used for consolidation purposes is also the spot rate from the second to last day of
the previous month and not an appropriate average rate as required and we have noted an immaterial
misstatement relating to the translation of I&E into the reporting currency (USD).
As the foreign exchange methodology is unchanged from the prior year, the matter therefore still
remains open in FY23.
In FY23 management performed a retrospective analysis to assess the misstatement caused by using
the incorrect foreign exchange rate. We have assessed this analysis and confirmed the completeness,
inputs and mathematical accuracy thereof. We have confirmed there is an immaterial misstatement
arising as a result of the effect of using the incorrect foreign exchange rates for income and
expenditure.
Cause:
The rates used, as noted above, are a spot rate from the second to last day of the prior month, not a
transaction date rate or suitable weighted average, or another alternative. The current system does not
allow for the correct rate to be used.
Effect:
Foreign exchange translation methodology is currently not in accordance with accounting standards.
There are differences within the Plan Inc. financial statements that have been identified but not
corrected as a result of the foreign exchange translation methodology issues noted.
Recommendation:
As management plan, design and configure the new ERP system consideration should be given to the
need to input foreign exchange rates into the system on a daily basis to ensure compliance with the
accounting standards and Plan’s accounting policies.
Views of Responsible Officials and Management’s Corrective Action Plan:
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-003: Classification, completeness and accuracy of bank accounts (significant
deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23
Pass-through: All applicable
Criteria:
Accurate and reliable financial records, including listing of bank accounts and bank reconciliations,
are necessary to ensure that testing populations are complete, accurate and bank accounts are
correctly classified.
Condition:
Plan Inc. holds over 550 bank accounts between Global Hub, Plan Ltd and the Country Offices. The
following points were noted during the Plan Inc. financial statement audit:
1. From our testing performed over opening and closing bank accounts at the regional hub level, we
noted an account which was classified as closed prior to receiving a formal letter from the bank
confirming the closure. The account remains open with a balance of €36.
2. In the bank confirmation we independently received from ECO Bank Cameroon we noted two
additional bank account balances of €212k (immaterial and below de minimis reporting threshold)
which were not included in the general ledger.
3. During our testing, differences in bank account numbers were noted in several instances between
either bank confirmations / bank statements / bank reconciliations compared to the bank account
listing which reflected the old account numbers. This was the case for accounts at five banks across
different Country Offices (‘CO’).
4. During our testing, differences in bank account numbers were noted from three bank
reconciliations (GL180090, GL180080, and GL168060) compared to the bank account listing as a
result of typos made on the bank reconciliations. The account numbers per Plan Inc. bank account
listing for these accounts, however, was correct.
5. During our testing, it was noted that two bank reconciliations (GL168010 and GL168110) had
incorrect local currencies input into the bank reconciliation in the currency field. This had no financial
impact on the bank reconciliations performed.
6. For two GL accounts (GL168120 and GL168129) differences amounting to €693,984 between the
denominated balance in bank reconciliation and the denominated balance per trial balance were
noted. Plan confirmed the amount pertains to the revaluation of currency and that the account should
not be reevaluated in local currency. This is a system error due to the wrong set up of the monthly
revaluation process for these two specific GL accounts.
Cause:
For the first point, Plan had acted on the request to close the bank account when the request had been
acknowledged but before it had been confirmed, and therefore removed the account from the cash
listing despite a formal confirmation letter from the bank not being received.
For the second, the root cause of this issue is the CO not following the process in relation to opening
bank accounts and appropriately informing Regional Hub (‘RH’) and Global Hub (‘GH’).
For points three and four, the revised bank account numbers were not updated on the bank account
listing which still contained the old account numbers; and for point five the CO had not picked up the
incorrect currency field noted or incorrect bank account number following review of the
reconciliation.
For the sixth point, two GL accounts had an incorrect variant set up causing differences between the
bank reconciliation and the trial balance.
Effect:
Classifying balances as closed creates risks over the completeness of the bank account listing. There is
a risk that a large number of accounts are classified as closed despite still being open or an account
with a material cash balance could be excluded from the cash listing.
Not identifying and reporting bank accounts on a timely basis to GH and bank account numbers
inaccurately reflected on the bank account listing or bank reconciliations creates risks over the
completeness of the bank account listing.
Per the Bank Secrecy Act, Plan is required through FBAR ( Foreign Bank and Financial Accounts, US
Federal Government) to report all non-US bank accounts to the US in March each year. FBAR then
performs ad hoc checks of various entities and if Plan is found not reporting a full list of active
accounts, they will receive penalty fines for not complying with US requirements.
Incorrect currencies or account numbers reflected on the bank reconciliations and bank fees not
included creates risk over the completeness and accuracy of bank reconciliations.
Additionally, the incorrect application of the variants creates the risk of inaccuracies performed on the
foreign currency translation of bank accounts.
Recommendation:
We recommend the following:
Bank accounts are not classified as closed until a formal closure letter from the bank is received.
The RHs perform timely monthly reviews to ensure the completeness of bank accounts and COs are
reminded of the process around opening and closing bank accounts and the required notifications to
RH and GH.
Management put in place a process whereby appropriate review of bank details is performed at a CO
level during the year end FBAR process as reliance is placed by GH on what is reported by the Country
Offices.
Management update the bank account listing to reflect updated bank account numbers.
Management ensure COs review the bank reconciliations for accuracy of financial and non-financial
data (such as account numbers).
Management ensure the correct set up of the monthly revaluation process for bank related GL
accounts.
Views of Responsible Officials and Management’s Corrective Action Plan :
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-004: Foreign exchange translation methodology (repeat of prior year finding 2022-004, 2021-005, 2020-006, 2019-006) (significant deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23, FY22, FY21, FY20 and FY19
Pass-through: All applicable
Criteria:
Accurate and reliable financial records of many kinds are necessary to meet ongoing financial
reporting and operational needs and requirements. The rate of exchange used throughout any given
month is the spot rate from the second to last working day of the prior month. This is not therefore the
‘the rate of exchange ruling at the date of the transaction’ in accordance with the Plan Inc. accounting
policies as stated in the financial statements.
Condition:
For all transactions, the impact of exchange rates takes place in the following stages:
At a transaction level
1. Translation from document currency (i.e. currency of income/expense per invoice) to local
currency at the time of initial recognition
2. Local currency to functional currency (Euro)
3. Translation to actual rate at date of settlement
4. Translation of outstanding amounts within the balance sheet at the period end rate
At the consolidation level
5. Functional currency to reporting currency (USD)
We note the following:
The monthly rate used for consolidation purposes is also the spot rate from the second to last day of
the previous month and not an appropriate average rate as required and we have noted an immaterial
misstatement relating to the translation of I&E into the reporting currency (USD).
As the foreign exchange methodology is unchanged from the prior year, the matter therefore still
remains open in FY23.
In FY23 management performed a retrospective analysis to assess the misstatement caused by using
the incorrect foreign exchange rate. We have assessed this analysis and confirmed the completeness,
inputs and mathematical accuracy thereof. We have confirmed there is an immaterial misstatement
arising as a result of the effect of using the incorrect foreign exchange rates for income and
expenditure.
Cause:
The rates used, as noted above, are a spot rate from the second to last day of the prior month, not a
transaction date rate or suitable weighted average, or another alternative. The current system does not
allow for the correct rate to be used.
Effect:
Foreign exchange translation methodology is currently not in accordance with accounting standards.
There are differences within the Plan Inc. financial statements that have been identified but not
corrected as a result of the foreign exchange translation methodology issues noted.
Recommendation:
As management plan, design and configure the new ERP system consideration should be given to the
need to input foreign exchange rates into the system on a daily basis to ensure compliance with the
accounting standards and Plan’s accounting policies.
Views of Responsible Officials and Management’s Corrective Action Plan:
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-003: Classification, completeness and accuracy of bank accounts (significant
deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23
Pass-through: All applicable
Criteria:
Accurate and reliable financial records, including listing of bank accounts and bank reconciliations,
are necessary to ensure that testing populations are complete, accurate and bank accounts are
correctly classified.
Condition:
Plan Inc. holds over 550 bank accounts between Global Hub, Plan Ltd and the Country Offices. The
following points were noted during the Plan Inc. financial statement audit:
1. From our testing performed over opening and closing bank accounts at the regional hub level, we
noted an account which was classified as closed prior to receiving a formal letter from the bank
confirming the closure. The account remains open with a balance of €36.
2. In the bank confirmation we independently received from ECO Bank Cameroon we noted two
additional bank account balances of €212k (immaterial and below de minimis reporting threshold)
which were not included in the general ledger.
3. During our testing, differences in bank account numbers were noted in several instances between
either bank confirmations / bank statements / bank reconciliations compared to the bank account
listing which reflected the old account numbers. This was the case for accounts at five banks across
different Country Offices (‘CO’).
4. During our testing, differences in bank account numbers were noted from three bank
reconciliations (GL180090, GL180080, and GL168060) compared to the bank account listing as a
result of typos made on the bank reconciliations. The account numbers per Plan Inc. bank account
listing for these accounts, however, was correct.
5. During our testing, it was noted that two bank reconciliations (GL168010 and GL168110) had
incorrect local currencies input into the bank reconciliation in the currency field. This had no financial
impact on the bank reconciliations performed.
6. For two GL accounts (GL168120 and GL168129) differences amounting to €693,984 between the
denominated balance in bank reconciliation and the denominated balance per trial balance were
noted. Plan confirmed the amount pertains to the revaluation of currency and that the account should
not be reevaluated in local currency. This is a system error due to the wrong set up of the monthly
revaluation process for these two specific GL accounts.
Cause:
For the first point, Plan had acted on the request to close the bank account when the request had been
acknowledged but before it had been confirmed, and therefore removed the account from the cash
listing despite a formal confirmation letter from the bank not being received.
For the second, the root cause of this issue is the CO not following the process in relation to opening
bank accounts and appropriately informing Regional Hub (‘RH’) and Global Hub (‘GH’).
For points three and four, the revised bank account numbers were not updated on the bank account
listing which still contained the old account numbers; and for point five the CO had not picked up the
incorrect currency field noted or incorrect bank account number following review of the
reconciliation.
For the sixth point, two GL accounts had an incorrect variant set up causing differences between the
bank reconciliation and the trial balance.
Effect:
Classifying balances as closed creates risks over the completeness of the bank account listing. There is
a risk that a large number of accounts are classified as closed despite still being open or an account
with a material cash balance could be excluded from the cash listing.
Not identifying and reporting bank accounts on a timely basis to GH and bank account numbers
inaccurately reflected on the bank account listing or bank reconciliations creates risks over the
completeness of the bank account listing.
Per the Bank Secrecy Act, Plan is required through FBAR ( Foreign Bank and Financial Accounts, US
Federal Government) to report all non-US bank accounts to the US in March each year. FBAR then
performs ad hoc checks of various entities and if Plan is found not reporting a full list of active
accounts, they will receive penalty fines for not complying with US requirements.
Incorrect currencies or account numbers reflected on the bank reconciliations and bank fees not
included creates risk over the completeness and accuracy of bank reconciliations.
Additionally, the incorrect application of the variants creates the risk of inaccuracies performed on the
foreign currency translation of bank accounts.
Recommendation:
We recommend the following:
Bank accounts are not classified as closed until a formal closure letter from the bank is received.
The RHs perform timely monthly reviews to ensure the completeness of bank accounts and COs are
reminded of the process around opening and closing bank accounts and the required notifications to
RH and GH.
Management put in place a process whereby appropriate review of bank details is performed at a CO
level during the year end FBAR process as reliance is placed by GH on what is reported by the Country
Offices.
Management update the bank account listing to reflect updated bank account numbers.
Management ensure COs review the bank reconciliations for accuracy of financial and non-financial
data (such as account numbers).
Management ensure the correct set up of the monthly revaluation process for bank related GL
accounts.
Views of Responsible Officials and Management’s Corrective Action Plan :
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-004: Foreign exchange translation methodology (repeat of prior year finding 2022-004, 2021-005, 2020-006, 2019-006) (significant deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23, FY22, FY21, FY20 and FY19
Pass-through: All applicable
Criteria:
Accurate and reliable financial records of many kinds are necessary to meet ongoing financial
reporting and operational needs and requirements. The rate of exchange used throughout any given
month is the spot rate from the second to last working day of the prior month. This is not therefore the
‘the rate of exchange ruling at the date of the transaction’ in accordance with the Plan Inc. accounting
policies as stated in the financial statements.
Condition:
For all transactions, the impact of exchange rates takes place in the following stages:
At a transaction level
1. Translation from document currency (i.e. currency of income/expense per invoice) to local
currency at the time of initial recognition
2. Local currency to functional currency (Euro)
3. Translation to actual rate at date of settlement
4. Translation of outstanding amounts within the balance sheet at the period end rate
At the consolidation level
5. Functional currency to reporting currency (USD)
We note the following:
The monthly rate used for consolidation purposes is also the spot rate from the second to last day of
the previous month and not an appropriate average rate as required and we have noted an immaterial
misstatement relating to the translation of I&E into the reporting currency (USD).
As the foreign exchange methodology is unchanged from the prior year, the matter therefore still
remains open in FY23.
In FY23 management performed a retrospective analysis to assess the misstatement caused by using
the incorrect foreign exchange rate. We have assessed this analysis and confirmed the completeness,
inputs and mathematical accuracy thereof. We have confirmed there is an immaterial misstatement
arising as a result of the effect of using the incorrect foreign exchange rates for income and
expenditure.
Cause:
The rates used, as noted above, are a spot rate from the second to last day of the prior month, not a
transaction date rate or suitable weighted average, or another alternative. The current system does not
allow for the correct rate to be used.
Effect:
Foreign exchange translation methodology is currently not in accordance with accounting standards.
There are differences within the Plan Inc. financial statements that have been identified but not
corrected as a result of the foreign exchange translation methodology issues noted.
Recommendation:
As management plan, design and configure the new ERP system consideration should be given to the
need to input foreign exchange rates into the system on a daily basis to ensure compliance with the
accounting standards and Plan’s accounting policies.
Views of Responsible Officials and Management’s Corrective Action Plan:
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-006: Documentation needs to be maintained to justify the rationale for
sole-source arrangements
Federal Agency: United States Agency for International Development (USAID) for Nigeria OTL
Program: Nigeria OTL
Assistance Listing: 98.001 (Nigeria OTL)
Award #: 72062021CA00006 NGA100152 (Nigeria OTL)
Award year: FY23
Pass-through: Plan USA, Inc.
Criteria:
Under 2 CFR 200.320(c) vendors above a micro-purchase threshold (currently $165 for Nigeria OTL,
which is more restrictive than the threshold in the Uniform Guidance) require a competitive process
that includes soliciting multiple bids/quotes to justify best value. The Uniform Guidance requires
purchasing decisions to be documented, including sole source justification, as applicable.
Condition :
We identified five transactions totalling $6,096 with two vendors where long-term arrangements
(LTA) were in place for the two vendors but documentation was not retained to demonstrate that a
competitive bid process had been performed prior to entering into the LTA.
We identified four transactions totalling $5,183 with one vendor where an LTA was in place, but the
LTA was extended with the same vendor without management documenting their rationale for sole
sourcing this arrangement. The original LTA dates back to 2018 and multiple vendors were initially
considered and documentation retained to demonstrate the initial tender at this point. However,
documentation was not retained regarding subsequent considerations around maintaining this
supplier under a sole source arrangement.
Cause:
Plan’s accounting policy is silent on a re-tender process should Plan choose to continue to use the
same vendor and as such LTAs were extended without retaining documentation that is required in
such instances under the Uniform Guidance.
Effect:
This could lead to missing out on better prospective vendors that management could do business with.
There is also a possibility of management bias to continue using the same vendor.
Recommendation:
Management should put in place policies and procedures that require retaining documentation to
justify the rationale for purchasing decisions consistent with the Uniform Guidance. We suggest that
management performs a re-tendering process at the end of any LTA prior to extending the contract or
otherwise documents the rationale for maintaining these suppliers under a sole source arrangement.
Views of Responsible Officials and Management’s Corrective Action Plan:
Views of responsible officials and management’s corrective action plan are included at the end of this
report after the summary schedule of prior audit findings and status.
Ref 2023-003: Classification, completeness and accuracy of bank accounts (significant
deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23
Pass-through: All applicable
Criteria:
Accurate and reliable financial records, including listing of bank accounts and bank reconciliations,
are necessary to ensure that testing populations are complete, accurate and bank accounts are
correctly classified.
Condition:
Plan Inc. holds over 550 bank accounts between Global Hub, Plan Ltd and the Country Offices. The
following points were noted during the Plan Inc. financial statement audit:
1. From our testing performed over opening and closing bank accounts at the regional hub level, we
noted an account which was classified as closed prior to receiving a formal letter from the bank
confirming the closure. The account remains open with a balance of €36.
2. In the bank confirmation we independently received from ECO Bank Cameroon we noted two
additional bank account balances of €212k (immaterial and below de minimis reporting threshold)
which were not included in the general ledger.
3. During our testing, differences in bank account numbers were noted in several instances between
either bank confirmations / bank statements / bank reconciliations compared to the bank account
listing which reflected the old account numbers. This was the case for accounts at five banks across
different Country Offices (‘CO’).
4. During our testing, differences in bank account numbers were noted from three bank
reconciliations (GL180090, GL180080, and GL168060) compared to the bank account listing as a
result of typos made on the bank reconciliations. The account numbers per Plan Inc. bank account
listing for these accounts, however, was correct.
5. During our testing, it was noted that two bank reconciliations (GL168010 and GL168110) had
incorrect local currencies input into the bank reconciliation in the currency field. This had no financial
impact on the bank reconciliations performed.
6. For two GL accounts (GL168120 and GL168129) differences amounting to €693,984 between the
denominated balance in bank reconciliation and the denominated balance per trial balance were
noted. Plan confirmed the amount pertains to the revaluation of currency and that the account should
not be reevaluated in local currency. This is a system error due to the wrong set up of the monthly
revaluation process for these two specific GL accounts.
Cause:
For the first point, Plan had acted on the request to close the bank account when the request had been
acknowledged but before it had been confirmed, and therefore removed the account from the cash
listing despite a formal confirmation letter from the bank not being received.
For the second, the root cause of this issue is the CO not following the process in relation to opening
bank accounts and appropriately informing Regional Hub (‘RH’) and Global Hub (‘GH’).
For points three and four, the revised bank account numbers were not updated on the bank account
listing which still contained the old account numbers; and for point five the CO had not picked up the
incorrect currency field noted or incorrect bank account number following review of the
reconciliation.
For the sixth point, two GL accounts had an incorrect variant set up causing differences between the
bank reconciliation and the trial balance.
Effect:
Classifying balances as closed creates risks over the completeness of the bank account listing. There is
a risk that a large number of accounts are classified as closed despite still being open or an account
with a material cash balance could be excluded from the cash listing.
Not identifying and reporting bank accounts on a timely basis to GH and bank account numbers
inaccurately reflected on the bank account listing or bank reconciliations creates risks over the
completeness of the bank account listing.
Per the Bank Secrecy Act, Plan is required through FBAR ( Foreign Bank and Financial Accounts, US
Federal Government) to report all non-US bank accounts to the US in March each year. FBAR then
performs ad hoc checks of various entities and if Plan is found not reporting a full list of active
accounts, they will receive penalty fines for not complying with US requirements.
Incorrect currencies or account numbers reflected on the bank reconciliations and bank fees not
included creates risk over the completeness and accuracy of bank reconciliations.
Additionally, the incorrect application of the variants creates the risk of inaccuracies performed on the
foreign currency translation of bank accounts.
Recommendation:
We recommend the following:
Bank accounts are not classified as closed until a formal closure letter from the bank is received.
The RHs perform timely monthly reviews to ensure the completeness of bank accounts and COs are
reminded of the process around opening and closing bank accounts and the required notifications to
RH and GH.
Management put in place a process whereby appropriate review of bank details is performed at a CO
level during the year end FBAR process as reliance is placed by GH on what is reported by the Country
Offices.
Management update the bank account listing to reflect updated bank account numbers.
Management ensure COs review the bank reconciliations for accuracy of financial and non-financial
data (such as account numbers).
Management ensure the correct set up of the monthly revaluation process for bank related GL
accounts.
Views of Responsible Officials and Management’s Corrective Action Plan :
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-004: Foreign exchange translation methodology (repeat of prior year finding 2022-004, 2021-005, 2020-006, 2019-006) (significant deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23, FY22, FY21, FY20 and FY19
Pass-through: All applicable
Criteria:
Accurate and reliable financial records of many kinds are necessary to meet ongoing financial
reporting and operational needs and requirements. The rate of exchange used throughout any given
month is the spot rate from the second to last working day of the prior month. This is not therefore the
‘the rate of exchange ruling at the date of the transaction’ in accordance with the Plan Inc. accounting
policies as stated in the financial statements.
Condition:
For all transactions, the impact of exchange rates takes place in the following stages:
At a transaction level
1. Translation from document currency (i.e. currency of income/expense per invoice) to local
currency at the time of initial recognition
2. Local currency to functional currency (Euro)
3. Translation to actual rate at date of settlement
4. Translation of outstanding amounts within the balance sheet at the period end rate
At the consolidation level
5. Functional currency to reporting currency (USD)
We note the following:
The monthly rate used for consolidation purposes is also the spot rate from the second to last day of
the previous month and not an appropriate average rate as required and we have noted an immaterial
misstatement relating to the translation of I&E into the reporting currency (USD).
As the foreign exchange methodology is unchanged from the prior year, the matter therefore still
remains open in FY23.
In FY23 management performed a retrospective analysis to assess the misstatement caused by using
the incorrect foreign exchange rate. We have assessed this analysis and confirmed the completeness,
inputs and mathematical accuracy thereof. We have confirmed there is an immaterial misstatement
arising as a result of the effect of using the incorrect foreign exchange rates for income and
expenditure.
Cause:
The rates used, as noted above, are a spot rate from the second to last day of the prior month, not a
transaction date rate or suitable weighted average, or another alternative. The current system does not
allow for the correct rate to be used.
Effect:
Foreign exchange translation methodology is currently not in accordance with accounting standards.
There are differences within the Plan Inc. financial statements that have been identified but not
corrected as a result of the foreign exchange translation methodology issues noted.
Recommendation:
As management plan, design and configure the new ERP system consideration should be given to the
need to input foreign exchange rates into the system on a daily basis to ensure compliance with the
accounting standards and Plan’s accounting policies.
Views of Responsible Officials and Management’s Corrective Action Plan:
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-003: Classification, completeness and accuracy of bank accounts (significant
deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23
Pass-through: All applicable
Criteria:
Accurate and reliable financial records, including listing of bank accounts and bank reconciliations,
are necessary to ensure that testing populations are complete, accurate and bank accounts are
correctly classified.
Condition:
Plan Inc. holds over 550 bank accounts between Global Hub, Plan Ltd and the Country Offices. The
following points were noted during the Plan Inc. financial statement audit:
1. From our testing performed over opening and closing bank accounts at the regional hub level, we
noted an account which was classified as closed prior to receiving a formal letter from the bank
confirming the closure. The account remains open with a balance of €36.
2. In the bank confirmation we independently received from ECO Bank Cameroon we noted two
additional bank account balances of €212k (immaterial and below de minimis reporting threshold)
which were not included in the general ledger.
3. During our testing, differences in bank account numbers were noted in several instances between
either bank confirmations / bank statements / bank reconciliations compared to the bank account
listing which reflected the old account numbers. This was the case for accounts at five banks across
different Country Offices (‘CO’).
4. During our testing, differences in bank account numbers were noted from three bank
reconciliations (GL180090, GL180080, and GL168060) compared to the bank account listing as a
result of typos made on the bank reconciliations. The account numbers per Plan Inc. bank account
listing for these accounts, however, was correct.
5. During our testing, it was noted that two bank reconciliations (GL168010 and GL168110) had
incorrect local currencies input into the bank reconciliation in the currency field. This had no financial
impact on the bank reconciliations performed.
6. For two GL accounts (GL168120 and GL168129) differences amounting to €693,984 between the
denominated balance in bank reconciliation and the denominated balance per trial balance were
noted. Plan confirmed the amount pertains to the revaluation of currency and that the account should
not be reevaluated in local currency. This is a system error due to the wrong set up of the monthly
revaluation process for these two specific GL accounts.
Cause:
For the first point, Plan had acted on the request to close the bank account when the request had been
acknowledged but before it had been confirmed, and therefore removed the account from the cash
listing despite a formal confirmation letter from the bank not being received.
For the second, the root cause of this issue is the CO not following the process in relation to opening
bank accounts and appropriately informing Regional Hub (‘RH’) and Global Hub (‘GH’).
For points three and four, the revised bank account numbers were not updated on the bank account
listing which still contained the old account numbers; and for point five the CO had not picked up the
incorrect currency field noted or incorrect bank account number following review of the
reconciliation.
For the sixth point, two GL accounts had an incorrect variant set up causing differences between the
bank reconciliation and the trial balance.
Effect:
Classifying balances as closed creates risks over the completeness of the bank account listing. There is
a risk that a large number of accounts are classified as closed despite still being open or an account
with a material cash balance could be excluded from the cash listing.
Not identifying and reporting bank accounts on a timely basis to GH and bank account numbers
inaccurately reflected on the bank account listing or bank reconciliations creates risks over the
completeness of the bank account listing.
Per the Bank Secrecy Act, Plan is required through FBAR ( Foreign Bank and Financial Accounts, US
Federal Government) to report all non-US bank accounts to the US in March each year. FBAR then
performs ad hoc checks of various entities and if Plan is found not reporting a full list of active
accounts, they will receive penalty fines for not complying with US requirements.
Incorrect currencies or account numbers reflected on the bank reconciliations and bank fees not
included creates risk over the completeness and accuracy of bank reconciliations.
Additionally, the incorrect application of the variants creates the risk of inaccuracies performed on the
foreign currency translation of bank accounts.
Recommendation:
We recommend the following:
Bank accounts are not classified as closed until a formal closure letter from the bank is received.
The RHs perform timely monthly reviews to ensure the completeness of bank accounts and COs are
reminded of the process around opening and closing bank accounts and the required notifications to
RH and GH.
Management put in place a process whereby appropriate review of bank details is performed at a CO
level during the year end FBAR process as reliance is placed by GH on what is reported by the Country
Offices.
Management update the bank account listing to reflect updated bank account numbers.
Management ensure COs review the bank reconciliations for accuracy of financial and non-financial
data (such as account numbers).
Management ensure the correct set up of the monthly revaluation process for bank related GL
accounts.
Views of Responsible Officials and Management’s Corrective Action Plan :
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-004: Foreign exchange translation methodology (repeat of prior year finding 2022-004, 2021-005, 2020-006, 2019-006) (significant deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23, FY22, FY21, FY20 and FY19
Pass-through: All applicable
Criteria:
Accurate and reliable financial records of many kinds are necessary to meet ongoing financial
reporting and operational needs and requirements. The rate of exchange used throughout any given
month is the spot rate from the second to last working day of the prior month. This is not therefore the
‘the rate of exchange ruling at the date of the transaction’ in accordance with the Plan Inc. accounting
policies as stated in the financial statements.
Condition:
For all transactions, the impact of exchange rates takes place in the following stages:
At a transaction level
1. Translation from document currency (i.e. currency of income/expense per invoice) to local
currency at the time of initial recognition
2. Local currency to functional currency (Euro)
3. Translation to actual rate at date of settlement
4. Translation of outstanding amounts within the balance sheet at the period end rate
At the consolidation level
5. Functional currency to reporting currency (USD)
We note the following:
The monthly rate used for consolidation purposes is also the spot rate from the second to last day of
the previous month and not an appropriate average rate as required and we have noted an immaterial
misstatement relating to the translation of I&E into the reporting currency (USD).
As the foreign exchange methodology is unchanged from the prior year, the matter therefore still
remains open in FY23.
In FY23 management performed a retrospective analysis to assess the misstatement caused by using
the incorrect foreign exchange rate. We have assessed this analysis and confirmed the completeness,
inputs and mathematical accuracy thereof. We have confirmed there is an immaterial misstatement
arising as a result of the effect of using the incorrect foreign exchange rates for income and
expenditure.
Cause:
The rates used, as noted above, are a spot rate from the second to last day of the prior month, not a
transaction date rate or suitable weighted average, or another alternative. The current system does not
allow for the correct rate to be used.
Effect:
Foreign exchange translation methodology is currently not in accordance with accounting standards.
There are differences within the Plan Inc. financial statements that have been identified but not
corrected as a result of the foreign exchange translation methodology issues noted.
Recommendation:
As management plan, design and configure the new ERP system consideration should be given to the
need to input foreign exchange rates into the system on a daily basis to ensure compliance with the
accounting standards and Plan’s accounting policies.
Views of Responsible Officials and Management’s Corrective Action Plan:
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-007: Suspension and debarment checks should be performed prior to doing
business with certain vendors
Federal Agency: U.S. Department of State for Ethiopia South Sudanese Refugee Assistance V and VI;
United States Agency for International Development (USAID)
Program: Ethiopia: South Sudanese Refugee Assistance V and VI; Ethiopia: BHA Tigray Child
Protection
Assistance Listing: 19.517 (Ethiopia); 98.001 (Ethiopia)
Award #: SPRMCO21CA3181 ETH102315 (Ethiopia), SPRMCO22CA0199 ETH102389 (Ethiopia);
720BHA21GR00199 ETH102324
Award year: FY23
Pass-through: Plan USA, Inc.
Criteria:
Non-federal entities are prohibited from contracting with or making subawards under covered
transactions to parties that are suspended or debarred. When a non-federal entity enters into a
covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as
defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or
otherwise excluded from participating in the transaction. This verification may be accomplished by (1)
checking the System for Award Management (SAM) Exclusions maintained by the General Services
Administration, (2) collecting a certification from the entity, or (3) adding a clause or condition to the
covered transaction with that entity (2 CFR section 180.300).
Condition :
Suspension and debarment checks are performed centrally by the compliance team based at Global
Hub (‘GH’). The compliance team obtains new vendor data from the finance system SAP on a weekly
basis and has a policy to check all vendors regardless of dollar value. Suspension and debarment
checks are performed over this list on a weekly basis using a third party ‘Automated Screening
Manager’ (‘ASM’) tool. In instances of one-off payments, the Country Office (‘CO’) sends a request via
email to the compliance team at GH to perform the suspension and debarment check. The results of
the ASM checks are shared with the COs.
We identified four samples out of a population of 67 samples where the date of the ASM check was
after the date of the transaction with the vendor. Management was therefore unable to evidence that a
suspension and debarment check had been performed prior to the transaction taking place. The time
period between the transaction dates of our samples and the date of the ASM checks ranged from one
day to 11 months.
The combined total of the four transactions was $19,108 and they occurred in one region (Ethiopia).
Cause:
The Global Hub compliance team was not notified on a timely basis of the new vendors by the
Ethiopia Country Office and therefore did not perform the suspension and debarment checks prior to
the transactions taking place.
Effect:
Vendors not checked if suspended or debarred prior to doing business with them could lead to
non-compliance to Uniform Guidance requirement.
Recommendation:
Management should ensure that COs are communicating with new vendors on a timely basis to ensure
that all vendors are checked for suspension and debarment before they are engaged and transacted
with and documentation is maintained demonstrating this check was completed.
Views of Responsible Officials and Management’s Corrective Action Plan:
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-003: Classification, completeness and accuracy of bank accounts (significant
deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23
Pass-through: All applicable
Criteria:
Accurate and reliable financial records, including listing of bank accounts and bank reconciliations,
are necessary to ensure that testing populations are complete, accurate and bank accounts are
correctly classified.
Condition:
Plan Inc. holds over 550 bank accounts between Global Hub, Plan Ltd and the Country Offices. The
following points were noted during the Plan Inc. financial statement audit:
1. From our testing performed over opening and closing bank accounts at the regional hub level, we
noted an account which was classified as closed prior to receiving a formal letter from the bank
confirming the closure. The account remains open with a balance of €36.
2. In the bank confirmation we independently received from ECO Bank Cameroon we noted two
additional bank account balances of €212k (immaterial and below de minimis reporting threshold)
which were not included in the general ledger.
3. During our testing, differences in bank account numbers were noted in several instances between
either bank confirmations / bank statements / bank reconciliations compared to the bank account
listing which reflected the old account numbers. This was the case for accounts at five banks across
different Country Offices (‘CO’).
4. During our testing, differences in bank account numbers were noted from three bank
reconciliations (GL180090, GL180080, and GL168060) compared to the bank account listing as a
result of typos made on the bank reconciliations. The account numbers per Plan Inc. bank account
listing for these accounts, however, was correct.
5. During our testing, it was noted that two bank reconciliations (GL168010 and GL168110) had
incorrect local currencies input into the bank reconciliation in the currency field. This had no financial
impact on the bank reconciliations performed.
6. For two GL accounts (GL168120 and GL168129) differences amounting to €693,984 between the
denominated balance in bank reconciliation and the denominated balance per trial balance were
noted. Plan confirmed the amount pertains to the revaluation of currency and that the account should
not be reevaluated in local currency. This is a system error due to the wrong set up of the monthly
revaluation process for these two specific GL accounts.
Cause:
For the first point, Plan had acted on the request to close the bank account when the request had been
acknowledged but before it had been confirmed, and therefore removed the account from the cash
listing despite a formal confirmation letter from the bank not being received.
For the second, the root cause of this issue is the CO not following the process in relation to opening
bank accounts and appropriately informing Regional Hub (‘RH’) and Global Hub (‘GH’).
For points three and four, the revised bank account numbers were not updated on the bank account
listing which still contained the old account numbers; and for point five the CO had not picked up the
incorrect currency field noted or incorrect bank account number following review of the
reconciliation.
For the sixth point, two GL accounts had an incorrect variant set up causing differences between the
bank reconciliation and the trial balance.
Effect:
Classifying balances as closed creates risks over the completeness of the bank account listing. There is
a risk that a large number of accounts are classified as closed despite still being open or an account
with a material cash balance could be excluded from the cash listing.
Not identifying and reporting bank accounts on a timely basis to GH and bank account numbers
inaccurately reflected on the bank account listing or bank reconciliations creates risks over the
completeness of the bank account listing.
Per the Bank Secrecy Act, Plan is required through FBAR ( Foreign Bank and Financial Accounts, US
Federal Government) to report all non-US bank accounts to the US in March each year. FBAR then
performs ad hoc checks of various entities and if Plan is found not reporting a full list of active
accounts, they will receive penalty fines for not complying with US requirements.
Incorrect currencies or account numbers reflected on the bank reconciliations and bank fees not
included creates risk over the completeness and accuracy of bank reconciliations.
Additionally, the incorrect application of the variants creates the risk of inaccuracies performed on the
foreign currency translation of bank accounts.
Recommendation:
We recommend the following:
Bank accounts are not classified as closed until a formal closure letter from the bank is received.
The RHs perform timely monthly reviews to ensure the completeness of bank accounts and COs are
reminded of the process around opening and closing bank accounts and the required notifications to
RH and GH.
Management put in place a process whereby appropriate review of bank details is performed at a CO
level during the year end FBAR process as reliance is placed by GH on what is reported by the Country
Offices.
Management update the bank account listing to reflect updated bank account numbers.
Management ensure COs review the bank reconciliations for accuracy of financial and non-financial
data (such as account numbers).
Management ensure the correct set up of the monthly revaluation process for bank related GL
accounts.
Views of Responsible Officials and Management’s Corrective Action Plan :
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-004: Foreign exchange translation methodology (repeat of prior year finding 2022-004, 2021-005, 2020-006, 2019-006) (significant deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23, FY22, FY21, FY20 and FY19
Pass-through: All applicable
Criteria:
Accurate and reliable financial records of many kinds are necessary to meet ongoing financial
reporting and operational needs and requirements. The rate of exchange used throughout any given
month is the spot rate from the second to last working day of the prior month. This is not therefore the
‘the rate of exchange ruling at the date of the transaction’ in accordance with the Plan Inc. accounting
policies as stated in the financial statements.
Condition:
For all transactions, the impact of exchange rates takes place in the following stages:
At a transaction level
1. Translation from document currency (i.e. currency of income/expense per invoice) to local
currency at the time of initial recognition
2. Local currency to functional currency (Euro)
3. Translation to actual rate at date of settlement
4. Translation of outstanding amounts within the balance sheet at the period end rate
At the consolidation level
5. Functional currency to reporting currency (USD)
We note the following:
The monthly rate used for consolidation purposes is also the spot rate from the second to last day of
the previous month and not an appropriate average rate as required and we have noted an immaterial
misstatement relating to the translation of I&E into the reporting currency (USD).
As the foreign exchange methodology is unchanged from the prior year, the matter therefore still
remains open in FY23.
In FY23 management performed a retrospective analysis to assess the misstatement caused by using
the incorrect foreign exchange rate. We have assessed this analysis and confirmed the completeness,
inputs and mathematical accuracy thereof. We have confirmed there is an immaterial misstatement
arising as a result of the effect of using the incorrect foreign exchange rates for income and
expenditure.
Cause:
The rates used, as noted above, are a spot rate from the second to last day of the prior month, not a
transaction date rate or suitable weighted average, or another alternative. The current system does not
allow for the correct rate to be used.
Effect:
Foreign exchange translation methodology is currently not in accordance with accounting standards.
There are differences within the Plan Inc. financial statements that have been identified but not
corrected as a result of the foreign exchange translation methodology issues noted.
Recommendation:
As management plan, design and configure the new ERP system consideration should be given to the
need to input foreign exchange rates into the system on a daily basis to ensure compliance with the
accounting standards and Plan’s accounting policies.
Views of Responsible Officials and Management’s Corrective Action Plan:
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-003: Classification, completeness and accuracy of bank accounts (significant
deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23
Pass-through: All applicable
Criteria:
Accurate and reliable financial records, including listing of bank accounts and bank reconciliations,
are necessary to ensure that testing populations are complete, accurate and bank accounts are
correctly classified.
Condition:
Plan Inc. holds over 550 bank accounts between Global Hub, Plan Ltd and the Country Offices. The
following points were noted during the Plan Inc. financial statement audit:
1. From our testing performed over opening and closing bank accounts at the regional hub level, we
noted an account which was classified as closed prior to receiving a formal letter from the bank
confirming the closure. The account remains open with a balance of €36.
2. In the bank confirmation we independently received from ECO Bank Cameroon we noted two
additional bank account balances of €212k (immaterial and below de minimis reporting threshold)
which were not included in the general ledger.
3. During our testing, differences in bank account numbers were noted in several instances between
either bank confirmations / bank statements / bank reconciliations compared to the bank account
listing which reflected the old account numbers. This was the case for accounts at five banks across
different Country Offices (‘CO’).
4. During our testing, differences in bank account numbers were noted from three bank
reconciliations (GL180090, GL180080, and GL168060) compared to the bank account listing as a
result of typos made on the bank reconciliations. The account numbers per Plan Inc. bank account
listing for these accounts, however, was correct.
5. During our testing, it was noted that two bank reconciliations (GL168010 and GL168110) had
incorrect local currencies input into the bank reconciliation in the currency field. This had no financial
impact on the bank reconciliations performed.
6. For two GL accounts (GL168120 and GL168129) differences amounting to €693,984 between the
denominated balance in bank reconciliation and the denominated balance per trial balance were
noted. Plan confirmed the amount pertains to the revaluation of currency and that the account should
not be reevaluated in local currency. This is a system error due to the wrong set up of the monthly
revaluation process for these two specific GL accounts.
Cause:
For the first point, Plan had acted on the request to close the bank account when the request had been
acknowledged but before it had been confirmed, and therefore removed the account from the cash
listing despite a formal confirmation letter from the bank not being received.
For the second, the root cause of this issue is the CO not following the process in relation to opening
bank accounts and appropriately informing Regional Hub (‘RH’) and Global Hub (‘GH’).
For points three and four, the revised bank account numbers were not updated on the bank account
listing which still contained the old account numbers; and for point five the CO had not picked up the
incorrect currency field noted or incorrect bank account number following review of the
reconciliation.
For the sixth point, two GL accounts had an incorrect variant set up causing differences between the
bank reconciliation and the trial balance.
Effect:
Classifying balances as closed creates risks over the completeness of the bank account listing. There is
a risk that a large number of accounts are classified as closed despite still being open or an account
with a material cash balance could be excluded from the cash listing.
Not identifying and reporting bank accounts on a timely basis to GH and bank account numbers
inaccurately reflected on the bank account listing or bank reconciliations creates risks over the
completeness of the bank account listing.
Per the Bank Secrecy Act, Plan is required through FBAR ( Foreign Bank and Financial Accounts, US
Federal Government) to report all non-US bank accounts to the US in March each year. FBAR then
performs ad hoc checks of various entities and if Plan is found not reporting a full list of active
accounts, they will receive penalty fines for not complying with US requirements.
Incorrect currencies or account numbers reflected on the bank reconciliations and bank fees not
included creates risk over the completeness and accuracy of bank reconciliations.
Additionally, the incorrect application of the variants creates the risk of inaccuracies performed on the
foreign currency translation of bank accounts.
Recommendation:
We recommend the following:
Bank accounts are not classified as closed until a formal closure letter from the bank is received.
The RHs perform timely monthly reviews to ensure the completeness of bank accounts and COs are
reminded of the process around opening and closing bank accounts and the required notifications to
RH and GH.
Management put in place a process whereby appropriate review of bank details is performed at a CO
level during the year end FBAR process as reliance is placed by GH on what is reported by the Country
Offices.
Management update the bank account listing to reflect updated bank account numbers.
Management ensure COs review the bank reconciliations for accuracy of financial and non-financial
data (such as account numbers).
Management ensure the correct set up of the monthly revaluation process for bank related GL
accounts.
Views of Responsible Officials and Management’s Corrective Action Plan :
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-004: Foreign exchange translation methodology (repeat of prior year finding 2022-004, 2021-005, 2020-006, 2019-006) (significant deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23, FY22, FY21, FY20 and FY19
Pass-through: All applicable
Criteria:
Accurate and reliable financial records of many kinds are necessary to meet ongoing financial
reporting and operational needs and requirements. The rate of exchange used throughout any given
month is the spot rate from the second to last working day of the prior month. This is not therefore the
‘the rate of exchange ruling at the date of the transaction’ in accordance with the Plan Inc. accounting
policies as stated in the financial statements.
Condition:
For all transactions, the impact of exchange rates takes place in the following stages:
At a transaction level
1. Translation from document currency (i.e. currency of income/expense per invoice) to local
currency at the time of initial recognition
2. Local currency to functional currency (Euro)
3. Translation to actual rate at date of settlement
4. Translation of outstanding amounts within the balance sheet at the period end rate
At the consolidation level
5. Functional currency to reporting currency (USD)
We note the following:
The monthly rate used for consolidation purposes is also the spot rate from the second to last day of
the previous month and not an appropriate average rate as required and we have noted an immaterial
misstatement relating to the translation of I&E into the reporting currency (USD).
As the foreign exchange methodology is unchanged from the prior year, the matter therefore still
remains open in FY23.
In FY23 management performed a retrospective analysis to assess the misstatement caused by using
the incorrect foreign exchange rate. We have assessed this analysis and confirmed the completeness,
inputs and mathematical accuracy thereof. We have confirmed there is an immaterial misstatement
arising as a result of the effect of using the incorrect foreign exchange rates for income and
expenditure.
Cause:
The rates used, as noted above, are a spot rate from the second to last day of the prior month, not a
transaction date rate or suitable weighted average, or another alternative. The current system does not
allow for the correct rate to be used.
Effect:
Foreign exchange translation methodology is currently not in accordance with accounting standards.
There are differences within the Plan Inc. financial statements that have been identified but not
corrected as a result of the foreign exchange translation methodology issues noted.
Recommendation:
As management plan, design and configure the new ERP system consideration should be given to the
need to input foreign exchange rates into the system on a daily basis to ensure compliance with the
accounting standards and Plan’s accounting policies.
Views of Responsible Officials and Management’s Corrective Action Plan:
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-003: Classification, completeness and accuracy of bank accounts (significant
deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23
Pass-through: All applicable
Criteria:
Accurate and reliable financial records, including listing of bank accounts and bank reconciliations,
are necessary to ensure that testing populations are complete, accurate and bank accounts are
correctly classified.
Condition:
Plan Inc. holds over 550 bank accounts between Global Hub, Plan Ltd and the Country Offices. The
following points were noted during the Plan Inc. financial statement audit:
1. From our testing performed over opening and closing bank accounts at the regional hub level, we
noted an account which was classified as closed prior to receiving a formal letter from the bank
confirming the closure. The account remains open with a balance of €36.
2. In the bank confirmation we independently received from ECO Bank Cameroon we noted two
additional bank account balances of €212k (immaterial and below de minimis reporting threshold)
which were not included in the general ledger.
3. During our testing, differences in bank account numbers were noted in several instances between
either bank confirmations / bank statements / bank reconciliations compared to the bank account
listing which reflected the old account numbers. This was the case for accounts at five banks across
different Country Offices (‘CO’).
4. During our testing, differences in bank account numbers were noted from three bank
reconciliations (GL180090, GL180080, and GL168060) compared to the bank account listing as a
result of typos made on the bank reconciliations. The account numbers per Plan Inc. bank account
listing for these accounts, however, was correct.
5. During our testing, it was noted that two bank reconciliations (GL168010 and GL168110) had
incorrect local currencies input into the bank reconciliation in the currency field. This had no financial
impact on the bank reconciliations performed.
6. For two GL accounts (GL168120 and GL168129) differences amounting to €693,984 between the
denominated balance in bank reconciliation and the denominated balance per trial balance were
noted. Plan confirmed the amount pertains to the revaluation of currency and that the account should
not be reevaluated in local currency. This is a system error due to the wrong set up of the monthly
revaluation process for these two specific GL accounts.
Cause:
For the first point, Plan had acted on the request to close the bank account when the request had been
acknowledged but before it had been confirmed, and therefore removed the account from the cash
listing despite a formal confirmation letter from the bank not being received.
For the second, the root cause of this issue is the CO not following the process in relation to opening
bank accounts and appropriately informing Regional Hub (‘RH’) and Global Hub (‘GH’).
For points three and four, the revised bank account numbers were not updated on the bank account
listing which still contained the old account numbers; and for point five the CO had not picked up the
incorrect currency field noted or incorrect bank account number following review of the
reconciliation.
For the sixth point, two GL accounts had an incorrect variant set up causing differences between the
bank reconciliation and the trial balance.
Effect:
Classifying balances as closed creates risks over the completeness of the bank account listing. There is
a risk that a large number of accounts are classified as closed despite still being open or an account
with a material cash balance could be excluded from the cash listing.
Not identifying and reporting bank accounts on a timely basis to GH and bank account numbers
inaccurately reflected on the bank account listing or bank reconciliations creates risks over the
completeness of the bank account listing.
Per the Bank Secrecy Act, Plan is required through FBAR ( Foreign Bank and Financial Accounts, US
Federal Government) to report all non-US bank accounts to the US in March each year. FBAR then
performs ad hoc checks of various entities and if Plan is found not reporting a full list of active
accounts, they will receive penalty fines for not complying with US requirements.
Incorrect currencies or account numbers reflected on the bank reconciliations and bank fees not
included creates risk over the completeness and accuracy of bank reconciliations.
Additionally, the incorrect application of the variants creates the risk of inaccuracies performed on the
foreign currency translation of bank accounts.
Recommendation:
We recommend the following:
Bank accounts are not classified as closed until a formal closure letter from the bank is received.
The RHs perform timely monthly reviews to ensure the completeness of bank accounts and COs are
reminded of the process around opening and closing bank accounts and the required notifications to
RH and GH.
Management put in place a process whereby appropriate review of bank details is performed at a CO
level during the year end FBAR process as reliance is placed by GH on what is reported by the Country
Offices.
Management update the bank account listing to reflect updated bank account numbers.
Management ensure COs review the bank reconciliations for accuracy of financial and non-financial
data (such as account numbers).
Management ensure the correct set up of the monthly revaluation process for bank related GL
accounts.
Views of Responsible Officials and Management’s Corrective Action Plan :
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-004: Foreign exchange translation methodology (repeat of prior year finding 2022-004, 2021-005, 2020-006, 2019-006) (significant deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23, FY22, FY21, FY20 and FY19
Pass-through: All applicable
Criteria:
Accurate and reliable financial records of many kinds are necessary to meet ongoing financial
reporting and operational needs and requirements. The rate of exchange used throughout any given
month is the spot rate from the second to last working day of the prior month. This is not therefore the
‘the rate of exchange ruling at the date of the transaction’ in accordance with the Plan Inc. accounting
policies as stated in the financial statements.
Condition:
For all transactions, the impact of exchange rates takes place in the following stages:
At a transaction level
1. Translation from document currency (i.e. currency of income/expense per invoice) to local
currency at the time of initial recognition
2. Local currency to functional currency (Euro)
3. Translation to actual rate at date of settlement
4. Translation of outstanding amounts within the balance sheet at the period end rate
At the consolidation level
5. Functional currency to reporting currency (USD)
We note the following:
The monthly rate used for consolidation purposes is also the spot rate from the second to last day of
the previous month and not an appropriate average rate as required and we have noted an immaterial
misstatement relating to the translation of I&E into the reporting currency (USD).
As the foreign exchange methodology is unchanged from the prior year, the matter therefore still
remains open in FY23.
In FY23 management performed a retrospective analysis to assess the misstatement caused by using
the incorrect foreign exchange rate. We have assessed this analysis and confirmed the completeness,
inputs and mathematical accuracy thereof. We have confirmed there is an immaterial misstatement
arising as a result of the effect of using the incorrect foreign exchange rates for income and
expenditure.
Cause:
The rates used, as noted above, are a spot rate from the second to last day of the prior month, not a
transaction date rate or suitable weighted average, or another alternative. The current system does not
allow for the correct rate to be used.
Effect:
Foreign exchange translation methodology is currently not in accordance with accounting standards.
There are differences within the Plan Inc. financial statements that have been identified but not
corrected as a result of the foreign exchange translation methodology issues noted.
Recommendation:
As management plan, design and configure the new ERP system consideration should be given to the
need to input foreign exchange rates into the system on a daily basis to ensure compliance with the
accounting standards and Plan’s accounting policies.
Views of Responsible Officials and Management’s Corrective Action Plan:
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-003: Classification, completeness and accuracy of bank accounts (significant
deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23
Pass-through: All applicable
Criteria:
Accurate and reliable financial records, including listing of bank accounts and bank reconciliations,
are necessary to ensure that testing populations are complete, accurate and bank accounts are
correctly classified.
Condition:
Plan Inc. holds over 550 bank accounts between Global Hub, Plan Ltd and the Country Offices. The
following points were noted during the Plan Inc. financial statement audit:
1. From our testing performed over opening and closing bank accounts at the regional hub level, we
noted an account which was classified as closed prior to receiving a formal letter from the bank
confirming the closure. The account remains open with a balance of €36.
2. In the bank confirmation we independently received from ECO Bank Cameroon we noted two
additional bank account balances of €212k (immaterial and below de minimis reporting threshold)
which were not included in the general ledger.
3. During our testing, differences in bank account numbers were noted in several instances between
either bank confirmations / bank statements / bank reconciliations compared to the bank account
listing which reflected the old account numbers. This was the case for accounts at five banks across
different Country Offices (‘CO’).
4. During our testing, differences in bank account numbers were noted from three bank
reconciliations (GL180090, GL180080, and GL168060) compared to the bank account listing as a
result of typos made on the bank reconciliations. The account numbers per Plan Inc. bank account
listing for these accounts, however, was correct.
5. During our testing, it was noted that two bank reconciliations (GL168010 and GL168110) had
incorrect local currencies input into the bank reconciliation in the currency field. This had no financial
impact on the bank reconciliations performed.
6. For two GL accounts (GL168120 and GL168129) differences amounting to €693,984 between the
denominated balance in bank reconciliation and the denominated balance per trial balance were
noted. Plan confirmed the amount pertains to the revaluation of currency and that the account should
not be reevaluated in local currency. This is a system error due to the wrong set up of the monthly
revaluation process for these two specific GL accounts.
Cause:
For the first point, Plan had acted on the request to close the bank account when the request had been
acknowledged but before it had been confirmed, and therefore removed the account from the cash
listing despite a formal confirmation letter from the bank not being received.
For the second, the root cause of this issue is the CO not following the process in relation to opening
bank accounts and appropriately informing Regional Hub (‘RH’) and Global Hub (‘GH’).
For points three and four, the revised bank account numbers were not updated on the bank account
listing which still contained the old account numbers; and for point five the CO had not picked up the
incorrect currency field noted or incorrect bank account number following review of the
reconciliation.
For the sixth point, two GL accounts had an incorrect variant set up causing differences between the
bank reconciliation and the trial balance.
Effect:
Classifying balances as closed creates risks over the completeness of the bank account listing. There is
a risk that a large number of accounts are classified as closed despite still being open or an account
with a material cash balance could be excluded from the cash listing.
Not identifying and reporting bank accounts on a timely basis to GH and bank account numbers
inaccurately reflected on the bank account listing or bank reconciliations creates risks over the
completeness of the bank account listing.
Per the Bank Secrecy Act, Plan is required through FBAR ( Foreign Bank and Financial Accounts, US
Federal Government) to report all non-US bank accounts to the US in March each year. FBAR then
performs ad hoc checks of various entities and if Plan is found not reporting a full list of active
accounts, they will receive penalty fines for not complying with US requirements.
Incorrect currencies or account numbers reflected on the bank reconciliations and bank fees not
included creates risk over the completeness and accuracy of bank reconciliations.
Additionally, the incorrect application of the variants creates the risk of inaccuracies performed on the
foreign currency translation of bank accounts.
Recommendation:
We recommend the following:
Bank accounts are not classified as closed until a formal closure letter from the bank is received.
The RHs perform timely monthly reviews to ensure the completeness of bank accounts and COs are
reminded of the process around opening and closing bank accounts and the required notifications to
RH and GH.
Management put in place a process whereby appropriate review of bank details is performed at a CO
level during the year end FBAR process as reliance is placed by GH on what is reported by the Country
Offices.
Management update the bank account listing to reflect updated bank account numbers.
Management ensure COs review the bank reconciliations for accuracy of financial and non-financial
data (such as account numbers).
Management ensure the correct set up of the monthly revaluation process for bank related GL
accounts.
Views of Responsible Officials and Management’s Corrective Action Plan :
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-004: Foreign exchange translation methodology (repeat of prior year finding 2022-004, 2021-005, 2020-006, 2019-006) (significant deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23, FY22, FY21, FY20 and FY19
Pass-through: All applicable
Criteria:
Accurate and reliable financial records of many kinds are necessary to meet ongoing financial
reporting and operational needs and requirements. The rate of exchange used throughout any given
month is the spot rate from the second to last working day of the prior month. This is not therefore the
‘the rate of exchange ruling at the date of the transaction’ in accordance with the Plan Inc. accounting
policies as stated in the financial statements.
Condition:
For all transactions, the impact of exchange rates takes place in the following stages:
At a transaction level
1. Translation from document currency (i.e. currency of income/expense per invoice) to local
currency at the time of initial recognition
2. Local currency to functional currency (Euro)
3. Translation to actual rate at date of settlement
4. Translation of outstanding amounts within the balance sheet at the period end rate
At the consolidation level
5. Functional currency to reporting currency (USD)
We note the following:
The monthly rate used for consolidation purposes is also the spot rate from the second to last day of
the previous month and not an appropriate average rate as required and we have noted an immaterial
misstatement relating to the translation of I&E into the reporting currency (USD).
As the foreign exchange methodology is unchanged from the prior year, the matter therefore still
remains open in FY23.
In FY23 management performed a retrospective analysis to assess the misstatement caused by using
the incorrect foreign exchange rate. We have assessed this analysis and confirmed the completeness,
inputs and mathematical accuracy thereof. We have confirmed there is an immaterial misstatement
arising as a result of the effect of using the incorrect foreign exchange rates for income and
expenditure.
Cause:
The rates used, as noted above, are a spot rate from the second to last day of the prior month, not a
transaction date rate or suitable weighted average, or another alternative. The current system does not
allow for the correct rate to be used.
Effect:
Foreign exchange translation methodology is currently not in accordance with accounting standards.
There are differences within the Plan Inc. financial statements that have been identified but not
corrected as a result of the foreign exchange translation methodology issues noted.
Recommendation:
As management plan, design and configure the new ERP system consideration should be given to the
need to input foreign exchange rates into the system on a daily basis to ensure compliance with the
accounting standards and Plan’s accounting policies.
Views of Responsible Officials and Management’s Corrective Action Plan:
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-003: Classification, completeness and accuracy of bank accounts (significant
deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23
Pass-through: All applicable
Criteria:
Accurate and reliable financial records, including listing of bank accounts and bank reconciliations,
are necessary to ensure that testing populations are complete, accurate and bank accounts are
correctly classified.
Condition:
Plan Inc. holds over 550 bank accounts between Global Hub, Plan Ltd and the Country Offices. The
following points were noted during the Plan Inc. financial statement audit:
1. From our testing performed over opening and closing bank accounts at the regional hub level, we
noted an account which was classified as closed prior to receiving a formal letter from the bank
confirming the closure. The account remains open with a balance of €36.
2. In the bank confirmation we independently received from ECO Bank Cameroon we noted two
additional bank account balances of €212k (immaterial and below de minimis reporting threshold)
which were not included in the general ledger.
3. During our testing, differences in bank account numbers were noted in several instances between
either bank confirmations / bank statements / bank reconciliations compared to the bank account
listing which reflected the old account numbers. This was the case for accounts at five banks across
different Country Offices (‘CO’).
4. During our testing, differences in bank account numbers were noted from three bank
reconciliations (GL180090, GL180080, and GL168060) compared to the bank account listing as a
result of typos made on the bank reconciliations. The account numbers per Plan Inc. bank account
listing for these accounts, however, was correct.
5. During our testing, it was noted that two bank reconciliations (GL168010 and GL168110) had
incorrect local currencies input into the bank reconciliation in the currency field. This had no financial
impact on the bank reconciliations performed.
6. For two GL accounts (GL168120 and GL168129) differences amounting to €693,984 between the
denominated balance in bank reconciliation and the denominated balance per trial balance were
noted. Plan confirmed the amount pertains to the revaluation of currency and that the account should
not be reevaluated in local currency. This is a system error due to the wrong set up of the monthly
revaluation process for these two specific GL accounts.
Cause:
For the first point, Plan had acted on the request to close the bank account when the request had been
acknowledged but before it had been confirmed, and therefore removed the account from the cash
listing despite a formal confirmation letter from the bank not being received.
For the second, the root cause of this issue is the CO not following the process in relation to opening
bank accounts and appropriately informing Regional Hub (‘RH’) and Global Hub (‘GH’).
For points three and four, the revised bank account numbers were not updated on the bank account
listing which still contained the old account numbers; and for point five the CO had not picked up the
incorrect currency field noted or incorrect bank account number following review of the
reconciliation.
For the sixth point, two GL accounts had an incorrect variant set up causing differences between the
bank reconciliation and the trial balance.
Effect:
Classifying balances as closed creates risks over the completeness of the bank account listing. There is
a risk that a large number of accounts are classified as closed despite still being open or an account
with a material cash balance could be excluded from the cash listing.
Not identifying and reporting bank accounts on a timely basis to GH and bank account numbers
inaccurately reflected on the bank account listing or bank reconciliations creates risks over the
completeness of the bank account listing.
Per the Bank Secrecy Act, Plan is required through FBAR ( Foreign Bank and Financial Accounts, US
Federal Government) to report all non-US bank accounts to the US in March each year. FBAR then
performs ad hoc checks of various entities and if Plan is found not reporting a full list of active
accounts, they will receive penalty fines for not complying with US requirements.
Incorrect currencies or account numbers reflected on the bank reconciliations and bank fees not
included creates risk over the completeness and accuracy of bank reconciliations.
Additionally, the incorrect application of the variants creates the risk of inaccuracies performed on the
foreign currency translation of bank accounts.
Recommendation:
We recommend the following:
Bank accounts are not classified as closed until a formal closure letter from the bank is received.
The RHs perform timely monthly reviews to ensure the completeness of bank accounts and COs are
reminded of the process around opening and closing bank accounts and the required notifications to
RH and GH.
Management put in place a process whereby appropriate review of bank details is performed at a CO
level during the year end FBAR process as reliance is placed by GH on what is reported by the Country
Offices.
Management update the bank account listing to reflect updated bank account numbers.
Management ensure COs review the bank reconciliations for accuracy of financial and non-financial
data (such as account numbers).
Management ensure the correct set up of the monthly revaluation process for bank related GL
accounts.
Views of Responsible Officials and Management’s Corrective Action Plan :
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-004: Foreign exchange translation methodology (repeat of prior year finding 2022-004, 2021-005, 2020-006, 2019-006) (significant deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23, FY22, FY21, FY20 and FY19
Pass-through: All applicable
Criteria:
Accurate and reliable financial records of many kinds are necessary to meet ongoing financial
reporting and operational needs and requirements. The rate of exchange used throughout any given
month is the spot rate from the second to last working day of the prior month. This is not therefore the
‘the rate of exchange ruling at the date of the transaction’ in accordance with the Plan Inc. accounting
policies as stated in the financial statements.
Condition:
For all transactions, the impact of exchange rates takes place in the following stages:
At a transaction level
1. Translation from document currency (i.e. currency of income/expense per invoice) to local
currency at the time of initial recognition
2. Local currency to functional currency (Euro)
3. Translation to actual rate at date of settlement
4. Translation of outstanding amounts within the balance sheet at the period end rate
At the consolidation level
5. Functional currency to reporting currency (USD)
We note the following:
The monthly rate used for consolidation purposes is also the spot rate from the second to last day of
the previous month and not an appropriate average rate as required and we have noted an immaterial
misstatement relating to the translation of I&E into the reporting currency (USD).
As the foreign exchange methodology is unchanged from the prior year, the matter therefore still
remains open in FY23.
In FY23 management performed a retrospective analysis to assess the misstatement caused by using
the incorrect foreign exchange rate. We have assessed this analysis and confirmed the completeness,
inputs and mathematical accuracy thereof. We have confirmed there is an immaterial misstatement
arising as a result of the effect of using the incorrect foreign exchange rates for income and
expenditure.
Cause:
The rates used, as noted above, are a spot rate from the second to last day of the prior month, not a
transaction date rate or suitable weighted average, or another alternative. The current system does not
allow for the correct rate to be used.
Effect:
Foreign exchange translation methodology is currently not in accordance with accounting standards.
There are differences within the Plan Inc. financial statements that have been identified but not
corrected as a result of the foreign exchange translation methodology issues noted.
Recommendation:
As management plan, design and configure the new ERP system consideration should be given to the
need to input foreign exchange rates into the system on a daily basis to ensure compliance with the
accounting standards and Plan’s accounting policies.
Views of Responsible Officials and Management’s Corrective Action Plan:
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-003: Classification, completeness and accuracy of bank accounts (significant
deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23
Pass-through: All applicable
Criteria:
Accurate and reliable financial records, including listing of bank accounts and bank reconciliations,
are necessary to ensure that testing populations are complete, accurate and bank accounts are
correctly classified.
Condition:
Plan Inc. holds over 550 bank accounts between Global Hub, Plan Ltd and the Country Offices. The
following points were noted during the Plan Inc. financial statement audit:
1. From our testing performed over opening and closing bank accounts at the regional hub level, we
noted an account which was classified as closed prior to receiving a formal letter from the bank
confirming the closure. The account remains open with a balance of €36.
2. In the bank confirmation we independently received from ECO Bank Cameroon we noted two
additional bank account balances of €212k (immaterial and below de minimis reporting threshold)
which were not included in the general ledger.
3. During our testing, differences in bank account numbers were noted in several instances between
either bank confirmations / bank statements / bank reconciliations compared to the bank account
listing which reflected the old account numbers. This was the case for accounts at five banks across
different Country Offices (‘CO’).
4. During our testing, differences in bank account numbers were noted from three bank
reconciliations (GL180090, GL180080, and GL168060) compared to the bank account listing as a
result of typos made on the bank reconciliations. The account numbers per Plan Inc. bank account
listing for these accounts, however, was correct.
5. During our testing, it was noted that two bank reconciliations (GL168010 and GL168110) had
incorrect local currencies input into the bank reconciliation in the currency field. This had no financial
impact on the bank reconciliations performed.
6. For two GL accounts (GL168120 and GL168129) differences amounting to €693,984 between the
denominated balance in bank reconciliation and the denominated balance per trial balance were
noted. Plan confirmed the amount pertains to the revaluation of currency and that the account should
not be reevaluated in local currency. This is a system error due to the wrong set up of the monthly
revaluation process for these two specific GL accounts.
Cause:
For the first point, Plan had acted on the request to close the bank account when the request had been
acknowledged but before it had been confirmed, and therefore removed the account from the cash
listing despite a formal confirmation letter from the bank not being received.
For the second, the root cause of this issue is the CO not following the process in relation to opening
bank accounts and appropriately informing Regional Hub (‘RH’) and Global Hub (‘GH’).
For points three and four, the revised bank account numbers were not updated on the bank account
listing which still contained the old account numbers; and for point five the CO had not picked up the
incorrect currency field noted or incorrect bank account number following review of the
reconciliation.
For the sixth point, two GL accounts had an incorrect variant set up causing differences between the
bank reconciliation and the trial balance.
Effect:
Classifying balances as closed creates risks over the completeness of the bank account listing. There is
a risk that a large number of accounts are classified as closed despite still being open or an account
with a material cash balance could be excluded from the cash listing.
Not identifying and reporting bank accounts on a timely basis to GH and bank account numbers
inaccurately reflected on the bank account listing or bank reconciliations creates risks over the
completeness of the bank account listing.
Per the Bank Secrecy Act, Plan is required through FBAR ( Foreign Bank and Financial Accounts, US
Federal Government) to report all non-US bank accounts to the US in March each year. FBAR then
performs ad hoc checks of various entities and if Plan is found not reporting a full list of active
accounts, they will receive penalty fines for not complying with US requirements.
Incorrect currencies or account numbers reflected on the bank reconciliations and bank fees not
included creates risk over the completeness and accuracy of bank reconciliations.
Additionally, the incorrect application of the variants creates the risk of inaccuracies performed on the
foreign currency translation of bank accounts.
Recommendation:
We recommend the following:
Bank accounts are not classified as closed until a formal closure letter from the bank is received.
The RHs perform timely monthly reviews to ensure the completeness of bank accounts and COs are
reminded of the process around opening and closing bank accounts and the required notifications to
RH and GH.
Management put in place a process whereby appropriate review of bank details is performed at a CO
level during the year end FBAR process as reliance is placed by GH on what is reported by the Country
Offices.
Management update the bank account listing to reflect updated bank account numbers.
Management ensure COs review the bank reconciliations for accuracy of financial and non-financial
data (such as account numbers).
Management ensure the correct set up of the monthly revaluation process for bank related GL
accounts.
Views of Responsible Officials and Management’s Corrective Action Plan :
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-004: Foreign exchange translation methodology (repeat of prior year finding 2022-004, 2021-005, 2020-006, 2019-006) (significant deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23, FY22, FY21, FY20 and FY19
Pass-through: All applicable
Criteria:
Accurate and reliable financial records of many kinds are necessary to meet ongoing financial
reporting and operational needs and requirements. The rate of exchange used throughout any given
month is the spot rate from the second to last working day of the prior month. This is not therefore the
‘the rate of exchange ruling at the date of the transaction’ in accordance with the Plan Inc. accounting
policies as stated in the financial statements.
Condition:
For all transactions, the impact of exchange rates takes place in the following stages:
At a transaction level
1. Translation from document currency (i.e. currency of income/expense per invoice) to local
currency at the time of initial recognition
2. Local currency to functional currency (Euro)
3. Translation to actual rate at date of settlement
4. Translation of outstanding amounts within the balance sheet at the period end rate
At the consolidation level
5. Functional currency to reporting currency (USD)
We note the following:
The monthly rate used for consolidation purposes is also the spot rate from the second to last day of
the previous month and not an appropriate average rate as required and we have noted an immaterial
misstatement relating to the translation of I&E into the reporting currency (USD).
As the foreign exchange methodology is unchanged from the prior year, the matter therefore still
remains open in FY23.
In FY23 management performed a retrospective analysis to assess the misstatement caused by using
the incorrect foreign exchange rate. We have assessed this analysis and confirmed the completeness,
inputs and mathematical accuracy thereof. We have confirmed there is an immaterial misstatement
arising as a result of the effect of using the incorrect foreign exchange rates for income and
expenditure.
Cause:
The rates used, as noted above, are a spot rate from the second to last day of the prior month, not a
transaction date rate or suitable weighted average, or another alternative. The current system does not
allow for the correct rate to be used.
Effect:
Foreign exchange translation methodology is currently not in accordance with accounting standards.
There are differences within the Plan Inc. financial statements that have been identified but not
corrected as a result of the foreign exchange translation methodology issues noted.
Recommendation:
As management plan, design and configure the new ERP system consideration should be given to the
need to input foreign exchange rates into the system on a daily basis to ensure compliance with the
accounting standards and Plan’s accounting policies.
Views of Responsible Officials and Management’s Corrective Action Plan:
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-003: Classification, completeness and accuracy of bank accounts (significant
deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23
Pass-through: All applicable
Criteria:
Accurate and reliable financial records, including listing of bank accounts and bank reconciliations,
are necessary to ensure that testing populations are complete, accurate and bank accounts are
correctly classified.
Condition:
Plan Inc. holds over 550 bank accounts between Global Hub, Plan Ltd and the Country Offices. The
following points were noted during the Plan Inc. financial statement audit:
1. From our testing performed over opening and closing bank accounts at the regional hub level, we
noted an account which was classified as closed prior to receiving a formal letter from the bank
confirming the closure. The account remains open with a balance of €36.
2. In the bank confirmation we independently received from ECO Bank Cameroon we noted two
additional bank account balances of €212k (immaterial and below de minimis reporting threshold)
which were not included in the general ledger.
3. During our testing, differences in bank account numbers were noted in several instances between
either bank confirmations / bank statements / bank reconciliations compared to the bank account
listing which reflected the old account numbers. This was the case for accounts at five banks across
different Country Offices (‘CO’).
4. During our testing, differences in bank account numbers were noted from three bank
reconciliations (GL180090, GL180080, and GL168060) compared to the bank account listing as a
result of typos made on the bank reconciliations. The account numbers per Plan Inc. bank account
listing for these accounts, however, was correct.
5. During our testing, it was noted that two bank reconciliations (GL168010 and GL168110) had
incorrect local currencies input into the bank reconciliation in the currency field. This had no financial
impact on the bank reconciliations performed.
6. For two GL accounts (GL168120 and GL168129) differences amounting to €693,984 between the
denominated balance in bank reconciliation and the denominated balance per trial balance were
noted. Plan confirmed the amount pertains to the revaluation of currency and that the account should
not be reevaluated in local currency. This is a system error due to the wrong set up of the monthly
revaluation process for these two specific GL accounts.
Cause:
For the first point, Plan had acted on the request to close the bank account when the request had been
acknowledged but before it had been confirmed, and therefore removed the account from the cash
listing despite a formal confirmation letter from the bank not being received.
For the second, the root cause of this issue is the CO not following the process in relation to opening
bank accounts and appropriately informing Regional Hub (‘RH’) and Global Hub (‘GH’).
For points three and four, the revised bank account numbers were not updated on the bank account
listing which still contained the old account numbers; and for point five the CO had not picked up the
incorrect currency field noted or incorrect bank account number following review of the
reconciliation.
For the sixth point, two GL accounts had an incorrect variant set up causing differences between the
bank reconciliation and the trial balance.
Effect:
Classifying balances as closed creates risks over the completeness of the bank account listing. There is
a risk that a large number of accounts are classified as closed despite still being open or an account
with a material cash balance could be excluded from the cash listing.
Not identifying and reporting bank accounts on a timely basis to GH and bank account numbers
inaccurately reflected on the bank account listing or bank reconciliations creates risks over the
completeness of the bank account listing.
Per the Bank Secrecy Act, Plan is required through FBAR ( Foreign Bank and Financial Accounts, US
Federal Government) to report all non-US bank accounts to the US in March each year. FBAR then
performs ad hoc checks of various entities and if Plan is found not reporting a full list of active
accounts, they will receive penalty fines for not complying with US requirements.
Incorrect currencies or account numbers reflected on the bank reconciliations and bank fees not
included creates risk over the completeness and accuracy of bank reconciliations.
Additionally, the incorrect application of the variants creates the risk of inaccuracies performed on the
foreign currency translation of bank accounts.
Recommendation:
We recommend the following:
Bank accounts are not classified as closed until a formal closure letter from the bank is received.
The RHs perform timely monthly reviews to ensure the completeness of bank accounts and COs are
reminded of the process around opening and closing bank accounts and the required notifications to
RH and GH.
Management put in place a process whereby appropriate review of bank details is performed at a CO
level during the year end FBAR process as reliance is placed by GH on what is reported by the Country
Offices.
Management update the bank account listing to reflect updated bank account numbers.
Management ensure COs review the bank reconciliations for accuracy of financial and non-financial
data (such as account numbers).
Management ensure the correct set up of the monthly revaluation process for bank related GL
accounts.
Views of Responsible Officials and Management’s Corrective Action Plan :
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-004: Foreign exchange translation methodology (repeat of prior year finding 2022-004, 2021-005, 2020-006, 2019-006) (significant deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23, FY22, FY21, FY20 and FY19
Pass-through: All applicable
Criteria:
Accurate and reliable financial records of many kinds are necessary to meet ongoing financial
reporting and operational needs and requirements. The rate of exchange used throughout any given
month is the spot rate from the second to last working day of the prior month. This is not therefore the
‘the rate of exchange ruling at the date of the transaction’ in accordance with the Plan Inc. accounting
policies as stated in the financial statements.
Condition:
For all transactions, the impact of exchange rates takes place in the following stages:
At a transaction level
1. Translation from document currency (i.e. currency of income/expense per invoice) to local
currency at the time of initial recognition
2. Local currency to functional currency (Euro)
3. Translation to actual rate at date of settlement
4. Translation of outstanding amounts within the balance sheet at the period end rate
At the consolidation level
5. Functional currency to reporting currency (USD)
We note the following:
The monthly rate used for consolidation purposes is also the spot rate from the second to last day of
the previous month and not an appropriate average rate as required and we have noted an immaterial
misstatement relating to the translation of I&E into the reporting currency (USD).
As the foreign exchange methodology is unchanged from the prior year, the matter therefore still
remains open in FY23.
In FY23 management performed a retrospective analysis to assess the misstatement caused by using
the incorrect foreign exchange rate. We have assessed this analysis and confirmed the completeness,
inputs and mathematical accuracy thereof. We have confirmed there is an immaterial misstatement
arising as a result of the effect of using the incorrect foreign exchange rates for income and
expenditure.
Cause:
The rates used, as noted above, are a spot rate from the second to last day of the prior month, not a
transaction date rate or suitable weighted average, or another alternative. The current system does not
allow for the correct rate to be used.
Effect:
Foreign exchange translation methodology is currently not in accordance with accounting standards.
There are differences within the Plan Inc. financial statements that have been identified but not
corrected as a result of the foreign exchange translation methodology issues noted.
Recommendation:
As management plan, design and configure the new ERP system consideration should be given to the
need to input foreign exchange rates into the system on a daily basis to ensure compliance with the
accounting standards and Plan’s accounting policies.
Views of Responsible Officials and Management’s Corrective Action Plan:
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-003: Classification, completeness and accuracy of bank accounts (significant
deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23
Pass-through: All applicable
Criteria:
Accurate and reliable financial records, including listing of bank accounts and bank reconciliations,
are necessary to ensure that testing populations are complete, accurate and bank accounts are
correctly classified.
Condition:
Plan Inc. holds over 550 bank accounts between Global Hub, Plan Ltd and the Country Offices. The
following points were noted during the Plan Inc. financial statement audit:
1. From our testing performed over opening and closing bank accounts at the regional hub level, we
noted an account which was classified as closed prior to receiving a formal letter from the bank
confirming the closure. The account remains open with a balance of €36.
2. In the bank confirmation we independently received from ECO Bank Cameroon we noted two
additional bank account balances of €212k (immaterial and below de minimis reporting threshold)
which were not included in the general ledger.
3. During our testing, differences in bank account numbers were noted in several instances between
either bank confirmations / bank statements / bank reconciliations compared to the bank account
listing which reflected the old account numbers. This was the case for accounts at five banks across
different Country Offices (‘CO’).
4. During our testing, differences in bank account numbers were noted from three bank
reconciliations (GL180090, GL180080, and GL168060) compared to the bank account listing as a
result of typos made on the bank reconciliations. The account numbers per Plan Inc. bank account
listing for these accounts, however, was correct.
5. During our testing, it was noted that two bank reconciliations (GL168010 and GL168110) had
incorrect local currencies input into the bank reconciliation in the currency field. This had no financial
impact on the bank reconciliations performed.
6. For two GL accounts (GL168120 and GL168129) differences amounting to €693,984 between the
denominated balance in bank reconciliation and the denominated balance per trial balance were
noted. Plan confirmed the amount pertains to the revaluation of currency and that the account should
not be reevaluated in local currency. This is a system error due to the wrong set up of the monthly
revaluation process for these two specific GL accounts.
Cause:
For the first point, Plan had acted on the request to close the bank account when the request had been
acknowledged but before it had been confirmed, and therefore removed the account from the cash
listing despite a formal confirmation letter from the bank not being received.
For the second, the root cause of this issue is the CO not following the process in relation to opening
bank accounts and appropriately informing Regional Hub (‘RH’) and Global Hub (‘GH’).
For points three and four, the revised bank account numbers were not updated on the bank account
listing which still contained the old account numbers; and for point five the CO had not picked up the
incorrect currency field noted or incorrect bank account number following review of the
reconciliation.
For the sixth point, two GL accounts had an incorrect variant set up causing differences between the
bank reconciliation and the trial balance.
Effect:
Classifying balances as closed creates risks over the completeness of the bank account listing. There is
a risk that a large number of accounts are classified as closed despite still being open or an account
with a material cash balance could be excluded from the cash listing.
Not identifying and reporting bank accounts on a timely basis to GH and bank account numbers
inaccurately reflected on the bank account listing or bank reconciliations creates risks over the
completeness of the bank account listing.
Per the Bank Secrecy Act, Plan is required through FBAR ( Foreign Bank and Financial Accounts, US
Federal Government) to report all non-US bank accounts to the US in March each year. FBAR then
performs ad hoc checks of various entities and if Plan is found not reporting a full list of active
accounts, they will receive penalty fines for not complying with US requirements.
Incorrect currencies or account numbers reflected on the bank reconciliations and bank fees not
included creates risk over the completeness and accuracy of bank reconciliations.
Additionally, the incorrect application of the variants creates the risk of inaccuracies performed on the
foreign currency translation of bank accounts.
Recommendation:
We recommend the following:
Bank accounts are not classified as closed until a formal closure letter from the bank is received.
The RHs perform timely monthly reviews to ensure the completeness of bank accounts and COs are
reminded of the process around opening and closing bank accounts and the required notifications to
RH and GH.
Management put in place a process whereby appropriate review of bank details is performed at a CO
level during the year end FBAR process as reliance is placed by GH on what is reported by the Country
Offices.
Management update the bank account listing to reflect updated bank account numbers.
Management ensure COs review the bank reconciliations for accuracy of financial and non-financial
data (such as account numbers).
Management ensure the correct set up of the monthly revaluation process for bank related GL
accounts.
Views of Responsible Officials and Management’s Corrective Action Plan :
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-004: Foreign exchange translation methodology (repeat of prior year finding 2022-004, 2021-005, 2020-006, 2019-006) (significant deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23, FY22, FY21, FY20 and FY19
Pass-through: All applicable
Criteria:
Accurate and reliable financial records of many kinds are necessary to meet ongoing financial
reporting and operational needs and requirements. The rate of exchange used throughout any given
month is the spot rate from the second to last working day of the prior month. This is not therefore the
‘the rate of exchange ruling at the date of the transaction’ in accordance with the Plan Inc. accounting
policies as stated in the financial statements.
Condition:
For all transactions, the impact of exchange rates takes place in the following stages:
At a transaction level
1. Translation from document currency (i.e. currency of income/expense per invoice) to local
currency at the time of initial recognition
2. Local currency to functional currency (Euro)
3. Translation to actual rate at date of settlement
4. Translation of outstanding amounts within the balance sheet at the period end rate
At the consolidation level
5. Functional currency to reporting currency (USD)
We note the following:
The monthly rate used for consolidation purposes is also the spot rate from the second to last day of
the previous month and not an appropriate average rate as required and we have noted an immaterial
misstatement relating to the translation of I&E into the reporting currency (USD).
As the foreign exchange methodology is unchanged from the prior year, the matter therefore still
remains open in FY23.
In FY23 management performed a retrospective analysis to assess the misstatement caused by using
the incorrect foreign exchange rate. We have assessed this analysis and confirmed the completeness,
inputs and mathematical accuracy thereof. We have confirmed there is an immaterial misstatement
arising as a result of the effect of using the incorrect foreign exchange rates for income and
expenditure.
Cause:
The rates used, as noted above, are a spot rate from the second to last day of the prior month, not a
transaction date rate or suitable weighted average, or another alternative. The current system does not
allow for the correct rate to be used.
Effect:
Foreign exchange translation methodology is currently not in accordance with accounting standards.
There are differences within the Plan Inc. financial statements that have been identified but not
corrected as a result of the foreign exchange translation methodology issues noted.
Recommendation:
As management plan, design and configure the new ERP system consideration should be given to the
need to input foreign exchange rates into the system on a daily basis to ensure compliance with the
accounting standards and Plan’s accounting policies.
Views of Responsible Officials and Management’s Corrective Action Plan:
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-003: Classification, completeness and accuracy of bank accounts (significant
deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23
Pass-through: All applicable
Criteria:
Accurate and reliable financial records, including listing of bank accounts and bank reconciliations,
are necessary to ensure that testing populations are complete, accurate and bank accounts are
correctly classified.
Condition:
Plan Inc. holds over 550 bank accounts between Global Hub, Plan Ltd and the Country Offices. The
following points were noted during the Plan Inc. financial statement audit:
1. From our testing performed over opening and closing bank accounts at the regional hub level, we
noted an account which was classified as closed prior to receiving a formal letter from the bank
confirming the closure. The account remains open with a balance of €36.
2. In the bank confirmation we independently received from ECO Bank Cameroon we noted two
additional bank account balances of €212k (immaterial and below de minimis reporting threshold)
which were not included in the general ledger.
3. During our testing, differences in bank account numbers were noted in several instances between
either bank confirmations / bank statements / bank reconciliations compared to the bank account
listing which reflected the old account numbers. This was the case for accounts at five banks across
different Country Offices (‘CO’).
4. During our testing, differences in bank account numbers were noted from three bank
reconciliations (GL180090, GL180080, and GL168060) compared to the bank account listing as a
result of typos made on the bank reconciliations. The account numbers per Plan Inc. bank account
listing for these accounts, however, was correct.
5. During our testing, it was noted that two bank reconciliations (GL168010 and GL168110) had
incorrect local currencies input into the bank reconciliation in the currency field. This had no financial
impact on the bank reconciliations performed.
6. For two GL accounts (GL168120 and GL168129) differences amounting to €693,984 between the
denominated balance in bank reconciliation and the denominated balance per trial balance were
noted. Plan confirmed the amount pertains to the revaluation of currency and that the account should
not be reevaluated in local currency. This is a system error due to the wrong set up of the monthly
revaluation process for these two specific GL accounts.
Cause:
For the first point, Plan had acted on the request to close the bank account when the request had been
acknowledged but before it had been confirmed, and therefore removed the account from the cash
listing despite a formal confirmation letter from the bank not being received.
For the second, the root cause of this issue is the CO not following the process in relation to opening
bank accounts and appropriately informing Regional Hub (‘RH’) and Global Hub (‘GH’).
For points three and four, the revised bank account numbers were not updated on the bank account
listing which still contained the old account numbers; and for point five the CO had not picked up the
incorrect currency field noted or incorrect bank account number following review of the
reconciliation.
For the sixth point, two GL accounts had an incorrect variant set up causing differences between the
bank reconciliation and the trial balance.
Effect:
Classifying balances as closed creates risks over the completeness of the bank account listing. There is
a risk that a large number of accounts are classified as closed despite still being open or an account
with a material cash balance could be excluded from the cash listing.
Not identifying and reporting bank accounts on a timely basis to GH and bank account numbers
inaccurately reflected on the bank account listing or bank reconciliations creates risks over the
completeness of the bank account listing.
Per the Bank Secrecy Act, Plan is required through FBAR ( Foreign Bank and Financial Accounts, US
Federal Government) to report all non-US bank accounts to the US in March each year. FBAR then
performs ad hoc checks of various entities and if Plan is found not reporting a full list of active
accounts, they will receive penalty fines for not complying with US requirements.
Incorrect currencies or account numbers reflected on the bank reconciliations and bank fees not
included creates risk over the completeness and accuracy of bank reconciliations.
Additionally, the incorrect application of the variants creates the risk of inaccuracies performed on the
foreign currency translation of bank accounts.
Recommendation:
We recommend the following:
Bank accounts are not classified as closed until a formal closure letter from the bank is received.
The RHs perform timely monthly reviews to ensure the completeness of bank accounts and COs are
reminded of the process around opening and closing bank accounts and the required notifications to
RH and GH.
Management put in place a process whereby appropriate review of bank details is performed at a CO
level during the year end FBAR process as reliance is placed by GH on what is reported by the Country
Offices.
Management update the bank account listing to reflect updated bank account numbers.
Management ensure COs review the bank reconciliations for accuracy of financial and non-financial
data (such as account numbers).
Management ensure the correct set up of the monthly revaluation process for bank related GL
accounts.
Views of Responsible Officials and Management’s Corrective Action Plan :
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-004: Foreign exchange translation methodology (repeat of prior year finding 2022-004, 2021-005, 2020-006, 2019-006) (significant deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23, FY22, FY21, FY20 and FY19
Pass-through: All applicable
Criteria:
Accurate and reliable financial records of many kinds are necessary to meet ongoing financial
reporting and operational needs and requirements. The rate of exchange used throughout any given
month is the spot rate from the second to last working day of the prior month. This is not therefore the
‘the rate of exchange ruling at the date of the transaction’ in accordance with the Plan Inc. accounting
policies as stated in the financial statements.
Condition:
For all transactions, the impact of exchange rates takes place in the following stages:
At a transaction level
1. Translation from document currency (i.e. currency of income/expense per invoice) to local
currency at the time of initial recognition
2. Local currency to functional currency (Euro)
3. Translation to actual rate at date of settlement
4. Translation of outstanding amounts within the balance sheet at the period end rate
At the consolidation level
5. Functional currency to reporting currency (USD)
We note the following:
The monthly rate used for consolidation purposes is also the spot rate from the second to last day of
the previous month and not an appropriate average rate as required and we have noted an immaterial
misstatement relating to the translation of I&E into the reporting currency (USD).
As the foreign exchange methodology is unchanged from the prior year, the matter therefore still
remains open in FY23.
In FY23 management performed a retrospective analysis to assess the misstatement caused by using
the incorrect foreign exchange rate. We have assessed this analysis and confirmed the completeness,
inputs and mathematical accuracy thereof. We have confirmed there is an immaterial misstatement
arising as a result of the effect of using the incorrect foreign exchange rates for income and
expenditure.
Cause:
The rates used, as noted above, are a spot rate from the second to last day of the prior month, not a
transaction date rate or suitable weighted average, or another alternative. The current system does not
allow for the correct rate to be used.
Effect:
Foreign exchange translation methodology is currently not in accordance with accounting standards.
There are differences within the Plan Inc. financial statements that have been identified but not
corrected as a result of the foreign exchange translation methodology issues noted.
Recommendation:
As management plan, design and configure the new ERP system consideration should be given to the
need to input foreign exchange rates into the system on a daily basis to ensure compliance with the
accounting standards and Plan’s accounting policies.
Views of Responsible Officials and Management’s Corrective Action Plan:
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-003: Classification, completeness and accuracy of bank accounts (significant
deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23
Pass-through: All applicable
Criteria:
Accurate and reliable financial records, including listing of bank accounts and bank reconciliations,
are necessary to ensure that testing populations are complete, accurate and bank accounts are
correctly classified.
Condition:
Plan Inc. holds over 550 bank accounts between Global Hub, Plan Ltd and the Country Offices. The
following points were noted during the Plan Inc. financial statement audit:
1. From our testing performed over opening and closing bank accounts at the regional hub level, we
noted an account which was classified as closed prior to receiving a formal letter from the bank
confirming the closure. The account remains open with a balance of €36.
2. In the bank confirmation we independently received from ECO Bank Cameroon we noted two
additional bank account balances of €212k (immaterial and below de minimis reporting threshold)
which were not included in the general ledger.
3. During our testing, differences in bank account numbers were noted in several instances between
either bank confirmations / bank statements / bank reconciliations compared to the bank account
listing which reflected the old account numbers. This was the case for accounts at five banks across
different Country Offices (‘CO’).
4. During our testing, differences in bank account numbers were noted from three bank
reconciliations (GL180090, GL180080, and GL168060) compared to the bank account listing as a
result of typos made on the bank reconciliations. The account numbers per Plan Inc. bank account
listing for these accounts, however, was correct.
5. During our testing, it was noted that two bank reconciliations (GL168010 and GL168110) had
incorrect local currencies input into the bank reconciliation in the currency field. This had no financial
impact on the bank reconciliations performed.
6. For two GL accounts (GL168120 and GL168129) differences amounting to €693,984 between the
denominated balance in bank reconciliation and the denominated balance per trial balance were
noted. Plan confirmed the amount pertains to the revaluation of currency and that the account should
not be reevaluated in local currency. This is a system error due to the wrong set up of the monthly
revaluation process for these two specific GL accounts.
Cause:
For the first point, Plan had acted on the request to close the bank account when the request had been
acknowledged but before it had been confirmed, and therefore removed the account from the cash
listing despite a formal confirmation letter from the bank not being received.
For the second, the root cause of this issue is the CO not following the process in relation to opening
bank accounts and appropriately informing Regional Hub (‘RH’) and Global Hub (‘GH’).
For points three and four, the revised bank account numbers were not updated on the bank account
listing which still contained the old account numbers; and for point five the CO had not picked up the
incorrect currency field noted or incorrect bank account number following review of the
reconciliation.
For the sixth point, two GL accounts had an incorrect variant set up causing differences between the
bank reconciliation and the trial balance.
Effect:
Classifying balances as closed creates risks over the completeness of the bank account listing. There is
a risk that a large number of accounts are classified as closed despite still being open or an account
with a material cash balance could be excluded from the cash listing.
Not identifying and reporting bank accounts on a timely basis to GH and bank account numbers
inaccurately reflected on the bank account listing or bank reconciliations creates risks over the
completeness of the bank account listing.
Per the Bank Secrecy Act, Plan is required through FBAR ( Foreign Bank and Financial Accounts, US
Federal Government) to report all non-US bank accounts to the US in March each year. FBAR then
performs ad hoc checks of various entities and if Plan is found not reporting a full list of active
accounts, they will receive penalty fines for not complying with US requirements.
Incorrect currencies or account numbers reflected on the bank reconciliations and bank fees not
included creates risk over the completeness and accuracy of bank reconciliations.
Additionally, the incorrect application of the variants creates the risk of inaccuracies performed on the
foreign currency translation of bank accounts.
Recommendation:
We recommend the following:
Bank accounts are not classified as closed until a formal closure letter from the bank is received.
The RHs perform timely monthly reviews to ensure the completeness of bank accounts and COs are
reminded of the process around opening and closing bank accounts and the required notifications to
RH and GH.
Management put in place a process whereby appropriate review of bank details is performed at a CO
level during the year end FBAR process as reliance is placed by GH on what is reported by the Country
Offices.
Management update the bank account listing to reflect updated bank account numbers.
Management ensure COs review the bank reconciliations for accuracy of financial and non-financial
data (such as account numbers).
Management ensure the correct set up of the monthly revaluation process for bank related GL
accounts.
Views of Responsible Officials and Management’s Corrective Action Plan :
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-004: Foreign exchange translation methodology (repeat of prior year finding 2022-004, 2021-005, 2020-006, 2019-006) (significant deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23, FY22, FY21, FY20 and FY19
Pass-through: All applicable
Criteria:
Accurate and reliable financial records of many kinds are necessary to meet ongoing financial
reporting and operational needs and requirements. The rate of exchange used throughout any given
month is the spot rate from the second to last working day of the prior month. This is not therefore the
‘the rate of exchange ruling at the date of the transaction’ in accordance with the Plan Inc. accounting
policies as stated in the financial statements.
Condition:
For all transactions, the impact of exchange rates takes place in the following stages:
At a transaction level
1. Translation from document currency (i.e. currency of income/expense per invoice) to local
currency at the time of initial recognition
2. Local currency to functional currency (Euro)
3. Translation to actual rate at date of settlement
4. Translation of outstanding amounts within the balance sheet at the period end rate
At the consolidation level
5. Functional currency to reporting currency (USD)
We note the following:
The monthly rate used for consolidation purposes is also the spot rate from the second to last day of
the previous month and not an appropriate average rate as required and we have noted an immaterial
misstatement relating to the translation of I&E into the reporting currency (USD).
As the foreign exchange methodology is unchanged from the prior year, the matter therefore still
remains open in FY23.
In FY23 management performed a retrospective analysis to assess the misstatement caused by using
the incorrect foreign exchange rate. We have assessed this analysis and confirmed the completeness,
inputs and mathematical accuracy thereof. We have confirmed there is an immaterial misstatement
arising as a result of the effect of using the incorrect foreign exchange rates for income and
expenditure.
Cause:
The rates used, as noted above, are a spot rate from the second to last day of the prior month, not a
transaction date rate or suitable weighted average, or another alternative. The current system does not
allow for the correct rate to be used.
Effect:
Foreign exchange translation methodology is currently not in accordance with accounting standards.
There are differences within the Plan Inc. financial statements that have been identified but not
corrected as a result of the foreign exchange translation methodology issues noted.
Recommendation:
As management plan, design and configure the new ERP system consideration should be given to the
need to input foreign exchange rates into the system on a daily basis to ensure compliance with the
accounting standards and Plan’s accounting policies.
Views of Responsible Officials and Management’s Corrective Action Plan:
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-003: Classification, completeness and accuracy of bank accounts (significant
deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23
Pass-through: All applicable
Criteria:
Accurate and reliable financial records, including listing of bank accounts and bank reconciliations,
are necessary to ensure that testing populations are complete, accurate and bank accounts are
correctly classified.
Condition:
Plan Inc. holds over 550 bank accounts between Global Hub, Plan Ltd and the Country Offices. The
following points were noted during the Plan Inc. financial statement audit:
1. From our testing performed over opening and closing bank accounts at the regional hub level, we
noted an account which was classified as closed prior to receiving a formal letter from the bank
confirming the closure. The account remains open with a balance of €36.
2. In the bank confirmation we independently received from ECO Bank Cameroon we noted two
additional bank account balances of €212k (immaterial and below de minimis reporting threshold)
which were not included in the general ledger.
3. During our testing, differences in bank account numbers were noted in several instances between
either bank confirmations / bank statements / bank reconciliations compared to the bank account
listing which reflected the old account numbers. This was the case for accounts at five banks across
different Country Offices (‘CO’).
4. During our testing, differences in bank account numbers were noted from three bank
reconciliations (GL180090, GL180080, and GL168060) compared to the bank account listing as a
result of typos made on the bank reconciliations. The account numbers per Plan Inc. bank account
listing for these accounts, however, was correct.
5. During our testing, it was noted that two bank reconciliations (GL168010 and GL168110) had
incorrect local currencies input into the bank reconciliation in the currency field. This had no financial
impact on the bank reconciliations performed.
6. For two GL accounts (GL168120 and GL168129) differences amounting to €693,984 between the
denominated balance in bank reconciliation and the denominated balance per trial balance were
noted. Plan confirmed the amount pertains to the revaluation of currency and that the account should
not be reevaluated in local currency. This is a system error due to the wrong set up of the monthly
revaluation process for these two specific GL accounts.
Cause:
For the first point, Plan had acted on the request to close the bank account when the request had been
acknowledged but before it had been confirmed, and therefore removed the account from the cash
listing despite a formal confirmation letter from the bank not being received.
For the second, the root cause of this issue is the CO not following the process in relation to opening
bank accounts and appropriately informing Regional Hub (‘RH’) and Global Hub (‘GH’).
For points three and four, the revised bank account numbers were not updated on the bank account
listing which still contained the old account numbers; and for point five the CO had not picked up the
incorrect currency field noted or incorrect bank account number following review of the
reconciliation.
For the sixth point, two GL accounts had an incorrect variant set up causing differences between the
bank reconciliation and the trial balance.
Effect:
Classifying balances as closed creates risks over the completeness of the bank account listing. There is
a risk that a large number of accounts are classified as closed despite still being open or an account
with a material cash balance could be excluded from the cash listing.
Not identifying and reporting bank accounts on a timely basis to GH and bank account numbers
inaccurately reflected on the bank account listing or bank reconciliations creates risks over the
completeness of the bank account listing.
Per the Bank Secrecy Act, Plan is required through FBAR ( Foreign Bank and Financial Accounts, US
Federal Government) to report all non-US bank accounts to the US in March each year. FBAR then
performs ad hoc checks of various entities and if Plan is found not reporting a full list of active
accounts, they will receive penalty fines for not complying with US requirements.
Incorrect currencies or account numbers reflected on the bank reconciliations and bank fees not
included creates risk over the completeness and accuracy of bank reconciliations.
Additionally, the incorrect application of the variants creates the risk of inaccuracies performed on the
foreign currency translation of bank accounts.
Recommendation:
We recommend the following:
Bank accounts are not classified as closed until a formal closure letter from the bank is received.
The RHs perform timely monthly reviews to ensure the completeness of bank accounts and COs are
reminded of the process around opening and closing bank accounts and the required notifications to
RH and GH.
Management put in place a process whereby appropriate review of bank details is performed at a CO
level during the year end FBAR process as reliance is placed by GH on what is reported by the Country
Offices.
Management update the bank account listing to reflect updated bank account numbers.
Management ensure COs review the bank reconciliations for accuracy of financial and non-financial
data (such as account numbers).
Management ensure the correct set up of the monthly revaluation process for bank related GL
accounts.
Views of Responsible Officials and Management’s Corrective Action Plan :
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-004: Foreign exchange translation methodology (repeat of prior year finding 2022-004, 2021-005, 2020-006, 2019-006) (significant deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23, FY22, FY21, FY20 and FY19
Pass-through: All applicable
Criteria:
Accurate and reliable financial records of many kinds are necessary to meet ongoing financial
reporting and operational needs and requirements. The rate of exchange used throughout any given
month is the spot rate from the second to last working day of the prior month. This is not therefore the
‘the rate of exchange ruling at the date of the transaction’ in accordance with the Plan Inc. accounting
policies as stated in the financial statements.
Condition:
For all transactions, the impact of exchange rates takes place in the following stages:
At a transaction level
1. Translation from document currency (i.e. currency of income/expense per invoice) to local
currency at the time of initial recognition
2. Local currency to functional currency (Euro)
3. Translation to actual rate at date of settlement
4. Translation of outstanding amounts within the balance sheet at the period end rate
At the consolidation level
5. Functional currency to reporting currency (USD)
We note the following:
The monthly rate used for consolidation purposes is also the spot rate from the second to last day of
the previous month and not an appropriate average rate as required and we have noted an immaterial
misstatement relating to the translation of I&E into the reporting currency (USD).
As the foreign exchange methodology is unchanged from the prior year, the matter therefore still
remains open in FY23.
In FY23 management performed a retrospective analysis to assess the misstatement caused by using
the incorrect foreign exchange rate. We have assessed this analysis and confirmed the completeness,
inputs and mathematical accuracy thereof. We have confirmed there is an immaterial misstatement
arising as a result of the effect of using the incorrect foreign exchange rates for income and
expenditure.
Cause:
The rates used, as noted above, are a spot rate from the second to last day of the prior month, not a
transaction date rate or suitable weighted average, or another alternative. The current system does not
allow for the correct rate to be used.
Effect:
Foreign exchange translation methodology is currently not in accordance with accounting standards.
There are differences within the Plan Inc. financial statements that have been identified but not
corrected as a result of the foreign exchange translation methodology issues noted.
Recommendation:
As management plan, design and configure the new ERP system consideration should be given to the
need to input foreign exchange rates into the system on a daily basis to ensure compliance with the
accounting standards and Plan’s accounting policies.
Views of Responsible Officials and Management’s Corrective Action Plan:
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-003: Classification, completeness and accuracy of bank accounts (significant
deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23
Pass-through: All applicable
Criteria:
Accurate and reliable financial records, including listing of bank accounts and bank reconciliations,
are necessary to ensure that testing populations are complete, accurate and bank accounts are
correctly classified.
Condition:
Plan Inc. holds over 550 bank accounts between Global Hub, Plan Ltd and the Country Offices. The
following points were noted during the Plan Inc. financial statement audit:
1. From our testing performed over opening and closing bank accounts at the regional hub level, we
noted an account which was classified as closed prior to receiving a formal letter from the bank
confirming the closure. The account remains open with a balance of €36.
2. In the bank confirmation we independently received from ECO Bank Cameroon we noted two
additional bank account balances of €212k (immaterial and below de minimis reporting threshold)
which were not included in the general ledger.
3. During our testing, differences in bank account numbers were noted in several instances between
either bank confirmations / bank statements / bank reconciliations compared to the bank account
listing which reflected the old account numbers. This was the case for accounts at five banks across
different Country Offices (‘CO’).
4. During our testing, differences in bank account numbers were noted from three bank
reconciliations (GL180090, GL180080, and GL168060) compared to the bank account listing as a
result of typos made on the bank reconciliations. The account numbers per Plan Inc. bank account
listing for these accounts, however, was correct.
5. During our testing, it was noted that two bank reconciliations (GL168010 and GL168110) had
incorrect local currencies input into the bank reconciliation in the currency field. This had no financial
impact on the bank reconciliations performed.
6. For two GL accounts (GL168120 and GL168129) differences amounting to €693,984 between the
denominated balance in bank reconciliation and the denominated balance per trial balance were
noted. Plan confirmed the amount pertains to the revaluation of currency and that the account should
not be reevaluated in local currency. This is a system error due to the wrong set up of the monthly
revaluation process for these two specific GL accounts.
Cause:
For the first point, Plan had acted on the request to close the bank account when the request had been
acknowledged but before it had been confirmed, and therefore removed the account from the cash
listing despite a formal confirmation letter from the bank not being received.
For the second, the root cause of this issue is the CO not following the process in relation to opening
bank accounts and appropriately informing Regional Hub (‘RH’) and Global Hub (‘GH’).
For points three and four, the revised bank account numbers were not updated on the bank account
listing which still contained the old account numbers; and for point five the CO had not picked up the
incorrect currency field noted or incorrect bank account number following review of the
reconciliation.
For the sixth point, two GL accounts had an incorrect variant set up causing differences between the
bank reconciliation and the trial balance.
Effect:
Classifying balances as closed creates risks over the completeness of the bank account listing. There is
a risk that a large number of accounts are classified as closed despite still being open or an account
with a material cash balance could be excluded from the cash listing.
Not identifying and reporting bank accounts on a timely basis to GH and bank account numbers
inaccurately reflected on the bank account listing or bank reconciliations creates risks over the
completeness of the bank account listing.
Per the Bank Secrecy Act, Plan is required through FBAR ( Foreign Bank and Financial Accounts, US
Federal Government) to report all non-US bank accounts to the US in March each year. FBAR then
performs ad hoc checks of various entities and if Plan is found not reporting a full list of active
accounts, they will receive penalty fines for not complying with US requirements.
Incorrect currencies or account numbers reflected on the bank reconciliations and bank fees not
included creates risk over the completeness and accuracy of bank reconciliations.
Additionally, the incorrect application of the variants creates the risk of inaccuracies performed on the
foreign currency translation of bank accounts.
Recommendation:
We recommend the following:
Bank accounts are not classified as closed until a formal closure letter from the bank is received.
The RHs perform timely monthly reviews to ensure the completeness of bank accounts and COs are
reminded of the process around opening and closing bank accounts and the required notifications to
RH and GH.
Management put in place a process whereby appropriate review of bank details is performed at a CO
level during the year end FBAR process as reliance is placed by GH on what is reported by the Country
Offices.
Management update the bank account listing to reflect updated bank account numbers.
Management ensure COs review the bank reconciliations for accuracy of financial and non-financial
data (such as account numbers).
Management ensure the correct set up of the monthly revaluation process for bank related GL
accounts.
Views of Responsible Officials and Management’s Corrective Action Plan :
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-004: Foreign exchange translation methodology (repeat of prior year finding 2022-004, 2021-005, 2020-006, 2019-006) (significant deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23, FY22, FY21, FY20 and FY19
Pass-through: All applicable
Criteria:
Accurate and reliable financial records of many kinds are necessary to meet ongoing financial
reporting and operational needs and requirements. The rate of exchange used throughout any given
month is the spot rate from the second to last working day of the prior month. This is not therefore the
‘the rate of exchange ruling at the date of the transaction’ in accordance with the Plan Inc. accounting
policies as stated in the financial statements.
Condition:
For all transactions, the impact of exchange rates takes place in the following stages:
At a transaction level
1. Translation from document currency (i.e. currency of income/expense per invoice) to local
currency at the time of initial recognition
2. Local currency to functional currency (Euro)
3. Translation to actual rate at date of settlement
4. Translation of outstanding amounts within the balance sheet at the period end rate
At the consolidation level
5. Functional currency to reporting currency (USD)
We note the following:
The monthly rate used for consolidation purposes is also the spot rate from the second to last day of
the previous month and not an appropriate average rate as required and we have noted an immaterial
misstatement relating to the translation of I&E into the reporting currency (USD).
As the foreign exchange methodology is unchanged from the prior year, the matter therefore still
remains open in FY23.
In FY23 management performed a retrospective analysis to assess the misstatement caused by using
the incorrect foreign exchange rate. We have assessed this analysis and confirmed the completeness,
inputs and mathematical accuracy thereof. We have confirmed there is an immaterial misstatement
arising as a result of the effect of using the incorrect foreign exchange rates for income and
expenditure.
Cause:
The rates used, as noted above, are a spot rate from the second to last day of the prior month, not a
transaction date rate or suitable weighted average, or another alternative. The current system does not
allow for the correct rate to be used.
Effect:
Foreign exchange translation methodology is currently not in accordance with accounting standards.
There are differences within the Plan Inc. financial statements that have been identified but not
corrected as a result of the foreign exchange translation methodology issues noted.
Recommendation:
As management plan, design and configure the new ERP system consideration should be given to the
need to input foreign exchange rates into the system on a daily basis to ensure compliance with the
accounting standards and Plan’s accounting policies.
Views of Responsible Officials and Management’s Corrective Action Plan:
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-003: Classification, completeness and accuracy of bank accounts (significant
deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23
Pass-through: All applicable
Criteria:
Accurate and reliable financial records, including listing of bank accounts and bank reconciliations,
are necessary to ensure that testing populations are complete, accurate and bank accounts are
correctly classified.
Condition:
Plan Inc. holds over 550 bank accounts between Global Hub, Plan Ltd and the Country Offices. The
following points were noted during the Plan Inc. financial statement audit:
1. From our testing performed over opening and closing bank accounts at the regional hub level, we
noted an account which was classified as closed prior to receiving a formal letter from the bank
confirming the closure. The account remains open with a balance of €36.
2. In the bank confirmation we independently received from ECO Bank Cameroon we noted two
additional bank account balances of €212k (immaterial and below de minimis reporting threshold)
which were not included in the general ledger.
3. During our testing, differences in bank account numbers were noted in several instances between
either bank confirmations / bank statements / bank reconciliations compared to the bank account
listing which reflected the old account numbers. This was the case for accounts at five banks across
different Country Offices (‘CO’).
4. During our testing, differences in bank account numbers were noted from three bank
reconciliations (GL180090, GL180080, and GL168060) compared to the bank account listing as a
result of typos made on the bank reconciliations. The account numbers per Plan Inc. bank account
listing for these accounts, however, was correct.
5. During our testing, it was noted that two bank reconciliations (GL168010 and GL168110) had
incorrect local currencies input into the bank reconciliation in the currency field. This had no financial
impact on the bank reconciliations performed.
6. For two GL accounts (GL168120 and GL168129) differences amounting to €693,984 between the
denominated balance in bank reconciliation and the denominated balance per trial balance were
noted. Plan confirmed the amount pertains to the revaluation of currency and that the account should
not be reevaluated in local currency. This is a system error due to the wrong set up of the monthly
revaluation process for these two specific GL accounts.
Cause:
For the first point, Plan had acted on the request to close the bank account when the request had been
acknowledged but before it had been confirmed, and therefore removed the account from the cash
listing despite a formal confirmation letter from the bank not being received.
For the second, the root cause of this issue is the CO not following the process in relation to opening
bank accounts and appropriately informing Regional Hub (‘RH’) and Global Hub (‘GH’).
For points three and four, the revised bank account numbers were not updated on the bank account
listing which still contained the old account numbers; and for point five the CO had not picked up the
incorrect currency field noted or incorrect bank account number following review of the
reconciliation.
For the sixth point, two GL accounts had an incorrect variant set up causing differences between the
bank reconciliation and the trial balance.
Effect:
Classifying balances as closed creates risks over the completeness of the bank account listing. There is
a risk that a large number of accounts are classified as closed despite still being open or an account
with a material cash balance could be excluded from the cash listing.
Not identifying and reporting bank accounts on a timely basis to GH and bank account numbers
inaccurately reflected on the bank account listing or bank reconciliations creates risks over the
completeness of the bank account listing.
Per the Bank Secrecy Act, Plan is required through FBAR ( Foreign Bank and Financial Accounts, US
Federal Government) to report all non-US bank accounts to the US in March each year. FBAR then
performs ad hoc checks of various entities and if Plan is found not reporting a full list of active
accounts, they will receive penalty fines for not complying with US requirements.
Incorrect currencies or account numbers reflected on the bank reconciliations and bank fees not
included creates risk over the completeness and accuracy of bank reconciliations.
Additionally, the incorrect application of the variants creates the risk of inaccuracies performed on the
foreign currency translation of bank accounts.
Recommendation:
We recommend the following:
Bank accounts are not classified as closed until a formal closure letter from the bank is received.
The RHs perform timely monthly reviews to ensure the completeness of bank accounts and COs are
reminded of the process around opening and closing bank accounts and the required notifications to
RH and GH.
Management put in place a process whereby appropriate review of bank details is performed at a CO
level during the year end FBAR process as reliance is placed by GH on what is reported by the Country
Offices.
Management update the bank account listing to reflect updated bank account numbers.
Management ensure COs review the bank reconciliations for accuracy of financial and non-financial
data (such as account numbers).
Management ensure the correct set up of the monthly revaluation process for bank related GL
accounts.
Views of Responsible Officials and Management’s Corrective Action Plan :
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-004: Foreign exchange translation methodology (repeat of prior year finding 2022-004, 2021-005, 2020-006, 2019-006) (significant deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23, FY22, FY21, FY20 and FY19
Pass-through: All applicable
Criteria:
Accurate and reliable financial records of many kinds are necessary to meet ongoing financial
reporting and operational needs and requirements. The rate of exchange used throughout any given
month is the spot rate from the second to last working day of the prior month. This is not therefore the
‘the rate of exchange ruling at the date of the transaction’ in accordance with the Plan Inc. accounting
policies as stated in the financial statements.
Condition:
For all transactions, the impact of exchange rates takes place in the following stages:
At a transaction level
1. Translation from document currency (i.e. currency of income/expense per invoice) to local
currency at the time of initial recognition
2. Local currency to functional currency (Euro)
3. Translation to actual rate at date of settlement
4. Translation of outstanding amounts within the balance sheet at the period end rate
At the consolidation level
5. Functional currency to reporting currency (USD)
We note the following:
The monthly rate used for consolidation purposes is also the spot rate from the second to last day of
the previous month and not an appropriate average rate as required and we have noted an immaterial
misstatement relating to the translation of I&E into the reporting currency (USD).
As the foreign exchange methodology is unchanged from the prior year, the matter therefore still
remains open in FY23.
In FY23 management performed a retrospective analysis to assess the misstatement caused by using
the incorrect foreign exchange rate. We have assessed this analysis and confirmed the completeness,
inputs and mathematical accuracy thereof. We have confirmed there is an immaterial misstatement
arising as a result of the effect of using the incorrect foreign exchange rates for income and
expenditure.
Cause:
The rates used, as noted above, are a spot rate from the second to last day of the prior month, not a
transaction date rate or suitable weighted average, or another alternative. The current system does not
allow for the correct rate to be used.
Effect:
Foreign exchange translation methodology is currently not in accordance with accounting standards.
There are differences within the Plan Inc. financial statements that have been identified but not
corrected as a result of the foreign exchange translation methodology issues noted.
Recommendation:
As management plan, design and configure the new ERP system consideration should be given to the
need to input foreign exchange rates into the system on a daily basis to ensure compliance with the
accounting standards and Plan’s accounting policies.
Views of Responsible Officials and Management’s Corrective Action Plan:
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-003: Classification, completeness and accuracy of bank accounts (significant
deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23
Pass-through: All applicable
Criteria:
Accurate and reliable financial records, including listing of bank accounts and bank reconciliations,
are necessary to ensure that testing populations are complete, accurate and bank accounts are
correctly classified.
Condition:
Plan Inc. holds over 550 bank accounts between Global Hub, Plan Ltd and the Country Offices. The
following points were noted during the Plan Inc. financial statement audit:
1. From our testing performed over opening and closing bank accounts at the regional hub level, we
noted an account which was classified as closed prior to receiving a formal letter from the bank
confirming the closure. The account remains open with a balance of €36.
2. In the bank confirmation we independently received from ECO Bank Cameroon we noted two
additional bank account balances of €212k (immaterial and below de minimis reporting threshold)
which were not included in the general ledger.
3. During our testing, differences in bank account numbers were noted in several instances between
either bank confirmations / bank statements / bank reconciliations compared to the bank account
listing which reflected the old account numbers. This was the case for accounts at five banks across
different Country Offices (‘CO’).
4. During our testing, differences in bank account numbers were noted from three bank
reconciliations (GL180090, GL180080, and GL168060) compared to the bank account listing as a
result of typos made on the bank reconciliations. The account numbers per Plan Inc. bank account
listing for these accounts, however, was correct.
5. During our testing, it was noted that two bank reconciliations (GL168010 and GL168110) had
incorrect local currencies input into the bank reconciliation in the currency field. This had no financial
impact on the bank reconciliations performed.
6. For two GL accounts (GL168120 and GL168129) differences amounting to €693,984 between the
denominated balance in bank reconciliation and the denominated balance per trial balance were
noted. Plan confirmed the amount pertains to the revaluation of currency and that the account should
not be reevaluated in local currency. This is a system error due to the wrong set up of the monthly
revaluation process for these two specific GL accounts.
Cause:
For the first point, Plan had acted on the request to close the bank account when the request had been
acknowledged but before it had been confirmed, and therefore removed the account from the cash
listing despite a formal confirmation letter from the bank not being received.
For the second, the root cause of this issue is the CO not following the process in relation to opening
bank accounts and appropriately informing Regional Hub (‘RH’) and Global Hub (‘GH’).
For points three and four, the revised bank account numbers were not updated on the bank account
listing which still contained the old account numbers; and for point five the CO had not picked up the
incorrect currency field noted or incorrect bank account number following review of the
reconciliation.
For the sixth point, two GL accounts had an incorrect variant set up causing differences between the
bank reconciliation and the trial balance.
Effect:
Classifying balances as closed creates risks over the completeness of the bank account listing. There is
a risk that a large number of accounts are classified as closed despite still being open or an account
with a material cash balance could be excluded from the cash listing.
Not identifying and reporting bank accounts on a timely basis to GH and bank account numbers
inaccurately reflected on the bank account listing or bank reconciliations creates risks over the
completeness of the bank account listing.
Per the Bank Secrecy Act, Plan is required through FBAR ( Foreign Bank and Financial Accounts, US
Federal Government) to report all non-US bank accounts to the US in March each year. FBAR then
performs ad hoc checks of various entities and if Plan is found not reporting a full list of active
accounts, they will receive penalty fines for not complying with US requirements.
Incorrect currencies or account numbers reflected on the bank reconciliations and bank fees not
included creates risk over the completeness and accuracy of bank reconciliations.
Additionally, the incorrect application of the variants creates the risk of inaccuracies performed on the
foreign currency translation of bank accounts.
Recommendation:
We recommend the following:
Bank accounts are not classified as closed until a formal closure letter from the bank is received.
The RHs perform timely monthly reviews to ensure the completeness of bank accounts and COs are
reminded of the process around opening and closing bank accounts and the required notifications to
RH and GH.
Management put in place a process whereby appropriate review of bank details is performed at a CO
level during the year end FBAR process as reliance is placed by GH on what is reported by the Country
Offices.
Management update the bank account listing to reflect updated bank account numbers.
Management ensure COs review the bank reconciliations for accuracy of financial and non-financial
data (such as account numbers).
Management ensure the correct set up of the monthly revaluation process for bank related GL
accounts.
Views of Responsible Officials and Management’s Corrective Action Plan :
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-004: Foreign exchange translation methodology (repeat of prior year finding 2022-004, 2021-005, 2020-006, 2019-006) (significant deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23, FY22, FY21, FY20 and FY19
Pass-through: All applicable
Criteria:
Accurate and reliable financial records of many kinds are necessary to meet ongoing financial
reporting and operational needs and requirements. The rate of exchange used throughout any given
month is the spot rate from the second to last working day of the prior month. This is not therefore the
‘the rate of exchange ruling at the date of the transaction’ in accordance with the Plan Inc. accounting
policies as stated in the financial statements.
Condition:
For all transactions, the impact of exchange rates takes place in the following stages:
At a transaction level
1. Translation from document currency (i.e. currency of income/expense per invoice) to local
currency at the time of initial recognition
2. Local currency to functional currency (Euro)
3. Translation to actual rate at date of settlement
4. Translation of outstanding amounts within the balance sheet at the period end rate
At the consolidation level
5. Functional currency to reporting currency (USD)
We note the following:
The monthly rate used for consolidation purposes is also the spot rate from the second to last day of
the previous month and not an appropriate average rate as required and we have noted an immaterial
misstatement relating to the translation of I&E into the reporting currency (USD).
As the foreign exchange methodology is unchanged from the prior year, the matter therefore still
remains open in FY23.
In FY23 management performed a retrospective analysis to assess the misstatement caused by using
the incorrect foreign exchange rate. We have assessed this analysis and confirmed the completeness,
inputs and mathematical accuracy thereof. We have confirmed there is an immaterial misstatement
arising as a result of the effect of using the incorrect foreign exchange rates for income and
expenditure.
Cause:
The rates used, as noted above, are a spot rate from the second to last day of the prior month, not a
transaction date rate or suitable weighted average, or another alternative. The current system does not
allow for the correct rate to be used.
Effect:
Foreign exchange translation methodology is currently not in accordance with accounting standards.
There are differences within the Plan Inc. financial statements that have been identified but not
corrected as a result of the foreign exchange translation methodology issues noted.
Recommendation:
As management plan, design and configure the new ERP system consideration should be given to the
need to input foreign exchange rates into the system on a daily basis to ensure compliance with the
accounting standards and Plan’s accounting policies.
Views of Responsible Officials and Management’s Corrective Action Plan:
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-003: Classification, completeness and accuracy of bank accounts (significant
deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23
Pass-through: All applicable
Criteria:
Accurate and reliable financial records, including listing of bank accounts and bank reconciliations,
are necessary to ensure that testing populations are complete, accurate and bank accounts are
correctly classified.
Condition:
Plan Inc. holds over 550 bank accounts between Global Hub, Plan Ltd and the Country Offices. The
following points were noted during the Plan Inc. financial statement audit:
1. From our testing performed over opening and closing bank accounts at the regional hub level, we
noted an account which was classified as closed prior to receiving a formal letter from the bank
confirming the closure. The account remains open with a balance of €36.
2. In the bank confirmation we independently received from ECO Bank Cameroon we noted two
additional bank account balances of €212k (immaterial and below de minimis reporting threshold)
which were not included in the general ledger.
3. During our testing, differences in bank account numbers were noted in several instances between
either bank confirmations / bank statements / bank reconciliations compared to the bank account
listing which reflected the old account numbers. This was the case for accounts at five banks across
different Country Offices (‘CO’).
4. During our testing, differences in bank account numbers were noted from three bank
reconciliations (GL180090, GL180080, and GL168060) compared to the bank account listing as a
result of typos made on the bank reconciliations. The account numbers per Plan Inc. bank account
listing for these accounts, however, was correct.
5. During our testing, it was noted that two bank reconciliations (GL168010 and GL168110) had
incorrect local currencies input into the bank reconciliation in the currency field. This had no financial
impact on the bank reconciliations performed.
6. For two GL accounts (GL168120 and GL168129) differences amounting to €693,984 between the
denominated balance in bank reconciliation and the denominated balance per trial balance were
noted. Plan confirmed the amount pertains to the revaluation of currency and that the account should
not be reevaluated in local currency. This is a system error due to the wrong set up of the monthly
revaluation process for these two specific GL accounts.
Cause:
For the first point, Plan had acted on the request to close the bank account when the request had been
acknowledged but before it had been confirmed, and therefore removed the account from the cash
listing despite a formal confirmation letter from the bank not being received.
For the second, the root cause of this issue is the CO not following the process in relation to opening
bank accounts and appropriately informing Regional Hub (‘RH’) and Global Hub (‘GH’).
For points three and four, the revised bank account numbers were not updated on the bank account
listing which still contained the old account numbers; and for point five the CO had not picked up the
incorrect currency field noted or incorrect bank account number following review of the
reconciliation.
For the sixth point, two GL accounts had an incorrect variant set up causing differences between the
bank reconciliation and the trial balance.
Effect:
Classifying balances as closed creates risks over the completeness of the bank account listing. There is
a risk that a large number of accounts are classified as closed despite still being open or an account
with a material cash balance could be excluded from the cash listing.
Not identifying and reporting bank accounts on a timely basis to GH and bank account numbers
inaccurately reflected on the bank account listing or bank reconciliations creates risks over the
completeness of the bank account listing.
Per the Bank Secrecy Act, Plan is required through FBAR ( Foreign Bank and Financial Accounts, US
Federal Government) to report all non-US bank accounts to the US in March each year. FBAR then
performs ad hoc checks of various entities and if Plan is found not reporting a full list of active
accounts, they will receive penalty fines for not complying with US requirements.
Incorrect currencies or account numbers reflected on the bank reconciliations and bank fees not
included creates risk over the completeness and accuracy of bank reconciliations.
Additionally, the incorrect application of the variants creates the risk of inaccuracies performed on the
foreign currency translation of bank accounts.
Recommendation:
We recommend the following:
Bank accounts are not classified as closed until a formal closure letter from the bank is received.
The RHs perform timely monthly reviews to ensure the completeness of bank accounts and COs are
reminded of the process around opening and closing bank accounts and the required notifications to
RH and GH.
Management put in place a process whereby appropriate review of bank details is performed at a CO
level during the year end FBAR process as reliance is placed by GH on what is reported by the Country
Offices.
Management update the bank account listing to reflect updated bank account numbers.
Management ensure COs review the bank reconciliations for accuracy of financial and non-financial
data (such as account numbers).
Management ensure the correct set up of the monthly revaluation process for bank related GL
accounts.
Views of Responsible Officials and Management’s Corrective Action Plan :
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-004: Foreign exchange translation methodology (repeat of prior year finding 2022-004, 2021-005, 2020-006, 2019-006) (significant deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23, FY22, FY21, FY20 and FY19
Pass-through: All applicable
Criteria:
Accurate and reliable financial records of many kinds are necessary to meet ongoing financial
reporting and operational needs and requirements. The rate of exchange used throughout any given
month is the spot rate from the second to last working day of the prior month. This is not therefore the
‘the rate of exchange ruling at the date of the transaction’ in accordance with the Plan Inc. accounting
policies as stated in the financial statements.
Condition:
For all transactions, the impact of exchange rates takes place in the following stages:
At a transaction level
1. Translation from document currency (i.e. currency of income/expense per invoice) to local
currency at the time of initial recognition
2. Local currency to functional currency (Euro)
3. Translation to actual rate at date of settlement
4. Translation of outstanding amounts within the balance sheet at the period end rate
At the consolidation level
5. Functional currency to reporting currency (USD)
We note the following:
The monthly rate used for consolidation purposes is also the spot rate from the second to last day of
the previous month and not an appropriate average rate as required and we have noted an immaterial
misstatement relating to the translation of I&E into the reporting currency (USD).
As the foreign exchange methodology is unchanged from the prior year, the matter therefore still
remains open in FY23.
In FY23 management performed a retrospective analysis to assess the misstatement caused by using
the incorrect foreign exchange rate. We have assessed this analysis and confirmed the completeness,
inputs and mathematical accuracy thereof. We have confirmed there is an immaterial misstatement
arising as a result of the effect of using the incorrect foreign exchange rates for income and
expenditure.
Cause:
The rates used, as noted above, are a spot rate from the second to last day of the prior month, not a
transaction date rate or suitable weighted average, or another alternative. The current system does not
allow for the correct rate to be used.
Effect:
Foreign exchange translation methodology is currently not in accordance with accounting standards.
There are differences within the Plan Inc. financial statements that have been identified but not
corrected as a result of the foreign exchange translation methodology issues noted.
Recommendation:
As management plan, design and configure the new ERP system consideration should be given to the
need to input foreign exchange rates into the system on a daily basis to ensure compliance with the
accounting standards and Plan’s accounting policies.
Views of Responsible Officials and Management’s Corrective Action Plan:
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-007: Suspension and debarment checks should be performed prior to doing
business with certain vendors
Federal Agency: U.S. Department of State for Ethiopia South Sudanese Refugee Assistance V and VI;
United States Agency for International Development (USAID)
Program: Ethiopia: South Sudanese Refugee Assistance V and VI; Ethiopia: BHA Tigray Child
Protection
Assistance Listing: 19.517 (Ethiopia); 98.001 (Ethiopia)
Award #: SPRMCO21CA3181 ETH102315 (Ethiopia), SPRMCO22CA0199 ETH102389 (Ethiopia);
720BHA21GR00199 ETH102324
Award year: FY23
Pass-through: Plan USA, Inc.
Criteria:
Non-federal entities are prohibited from contracting with or making subawards under covered
transactions to parties that are suspended or debarred. When a non-federal entity enters into a
covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as
defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or
otherwise excluded from participating in the transaction. This verification may be accomplished by (1)
checking the System for Award Management (SAM) Exclusions maintained by the General Services
Administration, (2) collecting a certification from the entity, or (3) adding a clause or condition to the
covered transaction with that entity (2 CFR section 180.300).
Condition :
Suspension and debarment checks are performed centrally by the compliance team based at Global
Hub (‘GH’). The compliance team obtains new vendor data from the finance system SAP on a weekly
basis and has a policy to check all vendors regardless of dollar value. Suspension and debarment
checks are performed over this list on a weekly basis using a third party ‘Automated Screening
Manager’ (‘ASM’) tool. In instances of one-off payments, the Country Office (‘CO’) sends a request via
email to the compliance team at GH to perform the suspension and debarment check. The results of
the ASM checks are shared with the COs.
We identified four samples out of a population of 67 samples where the date of the ASM check was
after the date of the transaction with the vendor. Management was therefore unable to evidence that a
suspension and debarment check had been performed prior to the transaction taking place. The time
period between the transaction dates of our samples and the date of the ASM checks ranged from one
day to 11 months.
The combined total of the four transactions was $19,108 and they occurred in one region (Ethiopia).
Cause:
The Global Hub compliance team was not notified on a timely basis of the new vendors by the
Ethiopia Country Office and therefore did not perform the suspension and debarment checks prior to
the transactions taking place.
Effect:
Vendors not checked if suspended or debarred prior to doing business with them could lead to
non-compliance to Uniform Guidance requirement.
Recommendation:
Management should ensure that COs are communicating with new vendors on a timely basis to ensure
that all vendors are checked for suspension and debarment before they are engaged and transacted
with and documentation is maintained demonstrating this check was completed.
Views of Responsible Officials and Management’s Corrective Action Plan:
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-003: Classification, completeness and accuracy of bank accounts (significant
deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23
Pass-through: All applicable
Criteria:
Accurate and reliable financial records, including listing of bank accounts and bank reconciliations,
are necessary to ensure that testing populations are complete, accurate and bank accounts are
correctly classified.
Condition:
Plan Inc. holds over 550 bank accounts between Global Hub, Plan Ltd and the Country Offices. The
following points were noted during the Plan Inc. financial statement audit:
1. From our testing performed over opening and closing bank accounts at the regional hub level, we
noted an account which was classified as closed prior to receiving a formal letter from the bank
confirming the closure. The account remains open with a balance of €36.
2. In the bank confirmation we independently received from ECO Bank Cameroon we noted two
additional bank account balances of €212k (immaterial and below de minimis reporting threshold)
which were not included in the general ledger.
3. During our testing, differences in bank account numbers were noted in several instances between
either bank confirmations / bank statements / bank reconciliations compared to the bank account
listing which reflected the old account numbers. This was the case for accounts at five banks across
different Country Offices (‘CO’).
4. During our testing, differences in bank account numbers were noted from three bank
reconciliations (GL180090, GL180080, and GL168060) compared to the bank account listing as a
result of typos made on the bank reconciliations. The account numbers per Plan Inc. bank account
listing for these accounts, however, was correct.
5. During our testing, it was noted that two bank reconciliations (GL168010 and GL168110) had
incorrect local currencies input into the bank reconciliation in the currency field. This had no financial
impact on the bank reconciliations performed.
6. For two GL accounts (GL168120 and GL168129) differences amounting to €693,984 between the
denominated balance in bank reconciliation and the denominated balance per trial balance were
noted. Plan confirmed the amount pertains to the revaluation of currency and that the account should
not be reevaluated in local currency. This is a system error due to the wrong set up of the monthly
revaluation process for these two specific GL accounts.
Cause:
For the first point, Plan had acted on the request to close the bank account when the request had been
acknowledged but before it had been confirmed, and therefore removed the account from the cash
listing despite a formal confirmation letter from the bank not being received.
For the second, the root cause of this issue is the CO not following the process in relation to opening
bank accounts and appropriately informing Regional Hub (‘RH’) and Global Hub (‘GH’).
For points three and four, the revised bank account numbers were not updated on the bank account
listing which still contained the old account numbers; and for point five the CO had not picked up the
incorrect currency field noted or incorrect bank account number following review of the
reconciliation.
For the sixth point, two GL accounts had an incorrect variant set up causing differences between the
bank reconciliation and the trial balance.
Effect:
Classifying balances as closed creates risks over the completeness of the bank account listing. There is
a risk that a large number of accounts are classified as closed despite still being open or an account
with a material cash balance could be excluded from the cash listing.
Not identifying and reporting bank accounts on a timely basis to GH and bank account numbers
inaccurately reflected on the bank account listing or bank reconciliations creates risks over the
completeness of the bank account listing.
Per the Bank Secrecy Act, Plan is required through FBAR ( Foreign Bank and Financial Accounts, US
Federal Government) to report all non-US bank accounts to the US in March each year. FBAR then
performs ad hoc checks of various entities and if Plan is found not reporting a full list of active
accounts, they will receive penalty fines for not complying with US requirements.
Incorrect currencies or account numbers reflected on the bank reconciliations and bank fees not
included creates risk over the completeness and accuracy of bank reconciliations.
Additionally, the incorrect application of the variants creates the risk of inaccuracies performed on the
foreign currency translation of bank accounts.
Recommendation:
We recommend the following:
Bank accounts are not classified as closed until a formal closure letter from the bank is received.
The RHs perform timely monthly reviews to ensure the completeness of bank accounts and COs are
reminded of the process around opening and closing bank accounts and the required notifications to
RH and GH.
Management put in place a process whereby appropriate review of bank details is performed at a CO
level during the year end FBAR process as reliance is placed by GH on what is reported by the Country
Offices.
Management update the bank account listing to reflect updated bank account numbers.
Management ensure COs review the bank reconciliations for accuracy of financial and non-financial
data (such as account numbers).
Management ensure the correct set up of the monthly revaluation process for bank related GL
accounts.
Views of Responsible Officials and Management’s Corrective Action Plan :
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-004: Foreign exchange translation methodology (repeat of prior year finding 2022-004, 2021-005, 2020-006, 2019-006) (significant deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23, FY22, FY21, FY20 and FY19
Pass-through: All applicable
Criteria:
Accurate and reliable financial records of many kinds are necessary to meet ongoing financial
reporting and operational needs and requirements. The rate of exchange used throughout any given
month is the spot rate from the second to last working day of the prior month. This is not therefore the
‘the rate of exchange ruling at the date of the transaction’ in accordance with the Plan Inc. accounting
policies as stated in the financial statements.
Condition:
For all transactions, the impact of exchange rates takes place in the following stages:
At a transaction level
1. Translation from document currency (i.e. currency of income/expense per invoice) to local
currency at the time of initial recognition
2. Local currency to functional currency (Euro)
3. Translation to actual rate at date of settlement
4. Translation of outstanding amounts within the balance sheet at the period end rate
At the consolidation level
5. Functional currency to reporting currency (USD)
We note the following:
The monthly rate used for consolidation purposes is also the spot rate from the second to last day of
the previous month and not an appropriate average rate as required and we have noted an immaterial
misstatement relating to the translation of I&E into the reporting currency (USD).
As the foreign exchange methodology is unchanged from the prior year, the matter therefore still
remains open in FY23.
In FY23 management performed a retrospective analysis to assess the misstatement caused by using
the incorrect foreign exchange rate. We have assessed this analysis and confirmed the completeness,
inputs and mathematical accuracy thereof. We have confirmed there is an immaterial misstatement
arising as a result of the effect of using the incorrect foreign exchange rates for income and
expenditure.
Cause:
The rates used, as noted above, are a spot rate from the second to last day of the prior month, not a
transaction date rate or suitable weighted average, or another alternative. The current system does not
allow for the correct rate to be used.
Effect:
Foreign exchange translation methodology is currently not in accordance with accounting standards.
There are differences within the Plan Inc. financial statements that have been identified but not
corrected as a result of the foreign exchange translation methodology issues noted.
Recommendation:
As management plan, design and configure the new ERP system consideration should be given to the
need to input foreign exchange rates into the system on a daily basis to ensure compliance with the
accounting standards and Plan’s accounting policies.
Views of Responsible Officials and Management’s Corrective Action Plan:
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-007: Suspension and debarment checks should be performed prior to doing
business with certain vendors
Federal Agency: U.S. Department of State for Ethiopia South Sudanese Refugee Assistance V and VI;
United States Agency for International Development (USAID)
Program: Ethiopia: South Sudanese Refugee Assistance V and VI; Ethiopia: BHA Tigray Child
Protection
Assistance Listing: 19.517 (Ethiopia); 98.001 (Ethiopia)
Award #: SPRMCO21CA3181 ETH102315 (Ethiopia), SPRMCO22CA0199 ETH102389 (Ethiopia);
720BHA21GR00199 ETH102324
Award year: FY23
Pass-through: Plan USA, Inc.
Criteria:
Non-federal entities are prohibited from contracting with or making subawards under covered
transactions to parties that are suspended or debarred. When a non-federal entity enters into a
covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as
defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or
otherwise excluded from participating in the transaction. This verification may be accomplished by (1)
checking the System for Award Management (SAM) Exclusions maintained by the General Services
Administration, (2) collecting a certification from the entity, or (3) adding a clause or condition to the
covered transaction with that entity (2 CFR section 180.300).
Condition :
Suspension and debarment checks are performed centrally by the compliance team based at Global
Hub (‘GH’). The compliance team obtains new vendor data from the finance system SAP on a weekly
basis and has a policy to check all vendors regardless of dollar value. Suspension and debarment
checks are performed over this list on a weekly basis using a third party ‘Automated Screening
Manager’ (‘ASM’) tool. In instances of one-off payments, the Country Office (‘CO’) sends a request via
email to the compliance team at GH to perform the suspension and debarment check. The results of
the ASM checks are shared with the COs.
We identified four samples out of a population of 67 samples where the date of the ASM check was
after the date of the transaction with the vendor. Management was therefore unable to evidence that a
suspension and debarment check had been performed prior to the transaction taking place. The time
period between the transaction dates of our samples and the date of the ASM checks ranged from one
day to 11 months.
The combined total of the four transactions was $19,108 and they occurred in one region (Ethiopia).
Cause:
The Global Hub compliance team was not notified on a timely basis of the new vendors by the
Ethiopia Country Office and therefore did not perform the suspension and debarment checks prior to
the transactions taking place.
Effect:
Vendors not checked if suspended or debarred prior to doing business with them could lead to
non-compliance to Uniform Guidance requirement.
Recommendation:
Management should ensure that COs are communicating with new vendors on a timely basis to ensure
that all vendors are checked for suspension and debarment before they are engaged and transacted
with and documentation is maintained demonstrating this check was completed.
Views of Responsible Officials and Management’s Corrective Action Plan:
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-003: Classification, completeness and accuracy of bank accounts (significant
deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23
Pass-through: All applicable
Criteria:
Accurate and reliable financial records, including listing of bank accounts and bank reconciliations,
are necessary to ensure that testing populations are complete, accurate and bank accounts are
correctly classified.
Condition:
Plan Inc. holds over 550 bank accounts between Global Hub, Plan Ltd and the Country Offices. The
following points were noted during the Plan Inc. financial statement audit:
1. From our testing performed over opening and closing bank accounts at the regional hub level, we
noted an account which was classified as closed prior to receiving a formal letter from the bank
confirming the closure. The account remains open with a balance of €36.
2. In the bank confirmation we independently received from ECO Bank Cameroon we noted two
additional bank account balances of €212k (immaterial and below de minimis reporting threshold)
which were not included in the general ledger.
3. During our testing, differences in bank account numbers were noted in several instances between
either bank confirmations / bank statements / bank reconciliations compared to the bank account
listing which reflected the old account numbers. This was the case for accounts at five banks across
different Country Offices (‘CO’).
4. During our testing, differences in bank account numbers were noted from three bank
reconciliations (GL180090, GL180080, and GL168060) compared to the bank account listing as a
result of typos made on the bank reconciliations. The account numbers per Plan Inc. bank account
listing for these accounts, however, was correct.
5. During our testing, it was noted that two bank reconciliations (GL168010 and GL168110) had
incorrect local currencies input into the bank reconciliation in the currency field. This had no financial
impact on the bank reconciliations performed.
6. For two GL accounts (GL168120 and GL168129) differences amounting to €693,984 between the
denominated balance in bank reconciliation and the denominated balance per trial balance were
noted. Plan confirmed the amount pertains to the revaluation of currency and that the account should
not be reevaluated in local currency. This is a system error due to the wrong set up of the monthly
revaluation process for these two specific GL accounts.
Cause:
For the first point, Plan had acted on the request to close the bank account when the request had been
acknowledged but before it had been confirmed, and therefore removed the account from the cash
listing despite a formal confirmation letter from the bank not being received.
For the second, the root cause of this issue is the CO not following the process in relation to opening
bank accounts and appropriately informing Regional Hub (‘RH’) and Global Hub (‘GH’).
For points three and four, the revised bank account numbers were not updated on the bank account
listing which still contained the old account numbers; and for point five the CO had not picked up the
incorrect currency field noted or incorrect bank account number following review of the
reconciliation.
For the sixth point, two GL accounts had an incorrect variant set up causing differences between the
bank reconciliation and the trial balance.
Effect:
Classifying balances as closed creates risks over the completeness of the bank account listing. There is
a risk that a large number of accounts are classified as closed despite still being open or an account
with a material cash balance could be excluded from the cash listing.
Not identifying and reporting bank accounts on a timely basis to GH and bank account numbers
inaccurately reflected on the bank account listing or bank reconciliations creates risks over the
completeness of the bank account listing.
Per the Bank Secrecy Act, Plan is required through FBAR ( Foreign Bank and Financial Accounts, US
Federal Government) to report all non-US bank accounts to the US in March each year. FBAR then
performs ad hoc checks of various entities and if Plan is found not reporting a full list of active
accounts, they will receive penalty fines for not complying with US requirements.
Incorrect currencies or account numbers reflected on the bank reconciliations and bank fees not
included creates risk over the completeness and accuracy of bank reconciliations.
Additionally, the incorrect application of the variants creates the risk of inaccuracies performed on the
foreign currency translation of bank accounts.
Recommendation:
We recommend the following:
Bank accounts are not classified as closed until a formal closure letter from the bank is received.
The RHs perform timely monthly reviews to ensure the completeness of bank accounts and COs are
reminded of the process around opening and closing bank accounts and the required notifications to
RH and GH.
Management put in place a process whereby appropriate review of bank details is performed at a CO
level during the year end FBAR process as reliance is placed by GH on what is reported by the Country
Offices.
Management update the bank account listing to reflect updated bank account numbers.
Management ensure COs review the bank reconciliations for accuracy of financial and non-financial
data (such as account numbers).
Management ensure the correct set up of the monthly revaluation process for bank related GL
accounts.
Views of Responsible Officials and Management’s Corrective Action Plan :
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-004: Foreign exchange translation methodology (repeat of prior year finding 2022-004, 2021-005, 2020-006, 2019-006) (significant deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23, FY22, FY21, FY20 and FY19
Pass-through: All applicable
Criteria:
Accurate and reliable financial records of many kinds are necessary to meet ongoing financial
reporting and operational needs and requirements. The rate of exchange used throughout any given
month is the spot rate from the second to last working day of the prior month. This is not therefore the
‘the rate of exchange ruling at the date of the transaction’ in accordance with the Plan Inc. accounting
policies as stated in the financial statements.
Condition:
For all transactions, the impact of exchange rates takes place in the following stages:
At a transaction level
1. Translation from document currency (i.e. currency of income/expense per invoice) to local
currency at the time of initial recognition
2. Local currency to functional currency (Euro)
3. Translation to actual rate at date of settlement
4. Translation of outstanding amounts within the balance sheet at the period end rate
At the consolidation level
5. Functional currency to reporting currency (USD)
We note the following:
The monthly rate used for consolidation purposes is also the spot rate from the second to last day of
the previous month and not an appropriate average rate as required and we have noted an immaterial
misstatement relating to the translation of I&E into the reporting currency (USD).
As the foreign exchange methodology is unchanged from the prior year, the matter therefore still
remains open in FY23.
In FY23 management performed a retrospective analysis to assess the misstatement caused by using
the incorrect foreign exchange rate. We have assessed this analysis and confirmed the completeness,
inputs and mathematical accuracy thereof. We have confirmed there is an immaterial misstatement
arising as a result of the effect of using the incorrect foreign exchange rates for income and
expenditure.
Cause:
The rates used, as noted above, are a spot rate from the second to last day of the prior month, not a
transaction date rate or suitable weighted average, or another alternative. The current system does not
allow for the correct rate to be used.
Effect:
Foreign exchange translation methodology is currently not in accordance with accounting standards.
There are differences within the Plan Inc. financial statements that have been identified but not
corrected as a result of the foreign exchange translation methodology issues noted.
Recommendation:
As management plan, design and configure the new ERP system consideration should be given to the
need to input foreign exchange rates into the system on a daily basis to ensure compliance with the
accounting standards and Plan’s accounting policies.
Views of Responsible Officials and Management’s Corrective Action Plan:
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-003: Classification, completeness and accuracy of bank accounts (significant
deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23
Pass-through: All applicable
Criteria:
Accurate and reliable financial records, including listing of bank accounts and bank reconciliations,
are necessary to ensure that testing populations are complete, accurate and bank accounts are
correctly classified.
Condition:
Plan Inc. holds over 550 bank accounts between Global Hub, Plan Ltd and the Country Offices. The
following points were noted during the Plan Inc. financial statement audit:
1. From our testing performed over opening and closing bank accounts at the regional hub level, we
noted an account which was classified as closed prior to receiving a formal letter from the bank
confirming the closure. The account remains open with a balance of €36.
2. In the bank confirmation we independently received from ECO Bank Cameroon we noted two
additional bank account balances of €212k (immaterial and below de minimis reporting threshold)
which were not included in the general ledger.
3. During our testing, differences in bank account numbers were noted in several instances between
either bank confirmations / bank statements / bank reconciliations compared to the bank account
listing which reflected the old account numbers. This was the case for accounts at five banks across
different Country Offices (‘CO’).
4. During our testing, differences in bank account numbers were noted from three bank
reconciliations (GL180090, GL180080, and GL168060) compared to the bank account listing as a
result of typos made on the bank reconciliations. The account numbers per Plan Inc. bank account
listing for these accounts, however, was correct.
5. During our testing, it was noted that two bank reconciliations (GL168010 and GL168110) had
incorrect local currencies input into the bank reconciliation in the currency field. This had no financial
impact on the bank reconciliations performed.
6. For two GL accounts (GL168120 and GL168129) differences amounting to €693,984 between the
denominated balance in bank reconciliation and the denominated balance per trial balance were
noted. Plan confirmed the amount pertains to the revaluation of currency and that the account should
not be reevaluated in local currency. This is a system error due to the wrong set up of the monthly
revaluation process for these two specific GL accounts.
Cause:
For the first point, Plan had acted on the request to close the bank account when the request had been
acknowledged but before it had been confirmed, and therefore removed the account from the cash
listing despite a formal confirmation letter from the bank not being received.
For the second, the root cause of this issue is the CO not following the process in relation to opening
bank accounts and appropriately informing Regional Hub (‘RH’) and Global Hub (‘GH’).
For points three and four, the revised bank account numbers were not updated on the bank account
listing which still contained the old account numbers; and for point five the CO had not picked up the
incorrect currency field noted or incorrect bank account number following review of the
reconciliation.
For the sixth point, two GL accounts had an incorrect variant set up causing differences between the
bank reconciliation and the trial balance.
Effect:
Classifying balances as closed creates risks over the completeness of the bank account listing. There is
a risk that a large number of accounts are classified as closed despite still being open or an account
with a material cash balance could be excluded from the cash listing.
Not identifying and reporting bank accounts on a timely basis to GH and bank account numbers
inaccurately reflected on the bank account listing or bank reconciliations creates risks over the
completeness of the bank account listing.
Per the Bank Secrecy Act, Plan is required through FBAR ( Foreign Bank and Financial Accounts, US
Federal Government) to report all non-US bank accounts to the US in March each year. FBAR then
performs ad hoc checks of various entities and if Plan is found not reporting a full list of active
accounts, they will receive penalty fines for not complying with US requirements.
Incorrect currencies or account numbers reflected on the bank reconciliations and bank fees not
included creates risk over the completeness and accuracy of bank reconciliations.
Additionally, the incorrect application of the variants creates the risk of inaccuracies performed on the
foreign currency translation of bank accounts.
Recommendation:
We recommend the following:
Bank accounts are not classified as closed until a formal closure letter from the bank is received.
The RHs perform timely monthly reviews to ensure the completeness of bank accounts and COs are
reminded of the process around opening and closing bank accounts and the required notifications to
RH and GH.
Management put in place a process whereby appropriate review of bank details is performed at a CO
level during the year end FBAR process as reliance is placed by GH on what is reported by the Country
Offices.
Management update the bank account listing to reflect updated bank account numbers.
Management ensure COs review the bank reconciliations for accuracy of financial and non-financial
data (such as account numbers).
Management ensure the correct set up of the monthly revaluation process for bank related GL
accounts.
Views of Responsible Officials and Management’s Corrective Action Plan :
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-004: Foreign exchange translation methodology (repeat of prior year finding 2022-004, 2021-005, 2020-006, 2019-006) (significant deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23, FY22, FY21, FY20 and FY19
Pass-through: All applicable
Criteria:
Accurate and reliable financial records of many kinds are necessary to meet ongoing financial
reporting and operational needs and requirements. The rate of exchange used throughout any given
month is the spot rate from the second to last working day of the prior month. This is not therefore the
‘the rate of exchange ruling at the date of the transaction’ in accordance with the Plan Inc. accounting
policies as stated in the financial statements.
Condition:
For all transactions, the impact of exchange rates takes place in the following stages:
At a transaction level
1. Translation from document currency (i.e. currency of income/expense per invoice) to local
currency at the time of initial recognition
2. Local currency to functional currency (Euro)
3. Translation to actual rate at date of settlement
4. Translation of outstanding amounts within the balance sheet at the period end rate
At the consolidation level
5. Functional currency to reporting currency (USD)
We note the following:
The monthly rate used for consolidation purposes is also the spot rate from the second to last day of
the previous month and not an appropriate average rate as required and we have noted an immaterial
misstatement relating to the translation of I&E into the reporting currency (USD).
As the foreign exchange methodology is unchanged from the prior year, the matter therefore still
remains open in FY23.
In FY23 management performed a retrospective analysis to assess the misstatement caused by using
the incorrect foreign exchange rate. We have assessed this analysis and confirmed the completeness,
inputs and mathematical accuracy thereof. We have confirmed there is an immaterial misstatement
arising as a result of the effect of using the incorrect foreign exchange rates for income and
expenditure.
Cause:
The rates used, as noted above, are a spot rate from the second to last day of the prior month, not a
transaction date rate or suitable weighted average, or another alternative. The current system does not
allow for the correct rate to be used.
Effect:
Foreign exchange translation methodology is currently not in accordance with accounting standards.
There are differences within the Plan Inc. financial statements that have been identified but not
corrected as a result of the foreign exchange translation methodology issues noted.
Recommendation:
As management plan, design and configure the new ERP system consideration should be given to the
need to input foreign exchange rates into the system on a daily basis to ensure compliance with the
accounting standards and Plan’s accounting policies.
Views of Responsible Officials and Management’s Corrective Action Plan:
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-003: Classification, completeness and accuracy of bank accounts (significant
deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23
Pass-through: All applicable
Criteria:
Accurate and reliable financial records, including listing of bank accounts and bank reconciliations,
are necessary to ensure that testing populations are complete, accurate and bank accounts are
correctly classified.
Condition:
Plan Inc. holds over 550 bank accounts between Global Hub, Plan Ltd and the Country Offices. The
following points were noted during the Plan Inc. financial statement audit:
1. From our testing performed over opening and closing bank accounts at the regional hub level, we
noted an account which was classified as closed prior to receiving a formal letter from the bank
confirming the closure. The account remains open with a balance of €36.
2. In the bank confirmation we independently received from ECO Bank Cameroon we noted two
additional bank account balances of €212k (immaterial and below de minimis reporting threshold)
which were not included in the general ledger.
3. During our testing, differences in bank account numbers were noted in several instances between
either bank confirmations / bank statements / bank reconciliations compared to the bank account
listing which reflected the old account numbers. This was the case for accounts at five banks across
different Country Offices (‘CO’).
4. During our testing, differences in bank account numbers were noted from three bank
reconciliations (GL180090, GL180080, and GL168060) compared to the bank account listing as a
result of typos made on the bank reconciliations. The account numbers per Plan Inc. bank account
listing for these accounts, however, was correct.
5. During our testing, it was noted that two bank reconciliations (GL168010 and GL168110) had
incorrect local currencies input into the bank reconciliation in the currency field. This had no financial
impact on the bank reconciliations performed.
6. For two GL accounts (GL168120 and GL168129) differences amounting to €693,984 between the
denominated balance in bank reconciliation and the denominated balance per trial balance were
noted. Plan confirmed the amount pertains to the revaluation of currency and that the account should
not be reevaluated in local currency. This is a system error due to the wrong set up of the monthly
revaluation process for these two specific GL accounts.
Cause:
For the first point, Plan had acted on the request to close the bank account when the request had been
acknowledged but before it had been confirmed, and therefore removed the account from the cash
listing despite a formal confirmation letter from the bank not being received.
For the second, the root cause of this issue is the CO not following the process in relation to opening
bank accounts and appropriately informing Regional Hub (‘RH’) and Global Hub (‘GH’).
For points three and four, the revised bank account numbers were not updated on the bank account
listing which still contained the old account numbers; and for point five the CO had not picked up the
incorrect currency field noted or incorrect bank account number following review of the
reconciliation.
For the sixth point, two GL accounts had an incorrect variant set up causing differences between the
bank reconciliation and the trial balance.
Effect:
Classifying balances as closed creates risks over the completeness of the bank account listing. There is
a risk that a large number of accounts are classified as closed despite still being open or an account
with a material cash balance could be excluded from the cash listing.
Not identifying and reporting bank accounts on a timely basis to GH and bank account numbers
inaccurately reflected on the bank account listing or bank reconciliations creates risks over the
completeness of the bank account listing.
Per the Bank Secrecy Act, Plan is required through FBAR ( Foreign Bank and Financial Accounts, US
Federal Government) to report all non-US bank accounts to the US in March each year. FBAR then
performs ad hoc checks of various entities and if Plan is found not reporting a full list of active
accounts, they will receive penalty fines for not complying with US requirements.
Incorrect currencies or account numbers reflected on the bank reconciliations and bank fees not
included creates risk over the completeness and accuracy of bank reconciliations.
Additionally, the incorrect application of the variants creates the risk of inaccuracies performed on the
foreign currency translation of bank accounts.
Recommendation:
We recommend the following:
Bank accounts are not classified as closed until a formal closure letter from the bank is received.
The RHs perform timely monthly reviews to ensure the completeness of bank accounts and COs are
reminded of the process around opening and closing bank accounts and the required notifications to
RH and GH.
Management put in place a process whereby appropriate review of bank details is performed at a CO
level during the year end FBAR process as reliance is placed by GH on what is reported by the Country
Offices.
Management update the bank account listing to reflect updated bank account numbers.
Management ensure COs review the bank reconciliations for accuracy of financial and non-financial
data (such as account numbers).
Management ensure the correct set up of the monthly revaluation process for bank related GL
accounts.
Views of Responsible Officials and Management’s Corrective Action Plan :
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-004: Foreign exchange translation methodology (repeat of prior year finding 2022-004, 2021-005, 2020-006, 2019-006) (significant deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23, FY22, FY21, FY20 and FY19
Pass-through: All applicable
Criteria:
Accurate and reliable financial records of many kinds are necessary to meet ongoing financial
reporting and operational needs and requirements. The rate of exchange used throughout any given
month is the spot rate from the second to last working day of the prior month. This is not therefore the
‘the rate of exchange ruling at the date of the transaction’ in accordance with the Plan Inc. accounting
policies as stated in the financial statements.
Condition:
For all transactions, the impact of exchange rates takes place in the following stages:
At a transaction level
1. Translation from document currency (i.e. currency of income/expense per invoice) to local
currency at the time of initial recognition
2. Local currency to functional currency (Euro)
3. Translation to actual rate at date of settlement
4. Translation of outstanding amounts within the balance sheet at the period end rate
At the consolidation level
5. Functional currency to reporting currency (USD)
We note the following:
The monthly rate used for consolidation purposes is also the spot rate from the second to last day of
the previous month and not an appropriate average rate as required and we have noted an immaterial
misstatement relating to the translation of I&E into the reporting currency (USD).
As the foreign exchange methodology is unchanged from the prior year, the matter therefore still
remains open in FY23.
In FY23 management performed a retrospective analysis to assess the misstatement caused by using
the incorrect foreign exchange rate. We have assessed this analysis and confirmed the completeness,
inputs and mathematical accuracy thereof. We have confirmed there is an immaterial misstatement
arising as a result of the effect of using the incorrect foreign exchange rates for income and
expenditure.
Cause:
The rates used, as noted above, are a spot rate from the second to last day of the prior month, not a
transaction date rate or suitable weighted average, or another alternative. The current system does not
allow for the correct rate to be used.
Effect:
Foreign exchange translation methodology is currently not in accordance with accounting standards.
There are differences within the Plan Inc. financial statements that have been identified but not
corrected as a result of the foreign exchange translation methodology issues noted.
Recommendation:
As management plan, design and configure the new ERP system consideration should be given to the
need to input foreign exchange rates into the system on a daily basis to ensure compliance with the
accounting standards and Plan’s accounting policies.
Views of Responsible Officials and Management’s Corrective Action Plan:
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-003: Classification, completeness and accuracy of bank accounts (significant
deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23
Pass-through: All applicable
Criteria:
Accurate and reliable financial records, including listing of bank accounts and bank reconciliations,
are necessary to ensure that testing populations are complete, accurate and bank accounts are
correctly classified.
Condition:
Plan Inc. holds over 550 bank accounts between Global Hub, Plan Ltd and the Country Offices. The
following points were noted during the Plan Inc. financial statement audit:
1. From our testing performed over opening and closing bank accounts at the regional hub level, we
noted an account which was classified as closed prior to receiving a formal letter from the bank
confirming the closure. The account remains open with a balance of €36.
2. In the bank confirmation we independently received from ECO Bank Cameroon we noted two
additional bank account balances of €212k (immaterial and below de minimis reporting threshold)
which were not included in the general ledger.
3. During our testing, differences in bank account numbers were noted in several instances between
either bank confirmations / bank statements / bank reconciliations compared to the bank account
listing which reflected the old account numbers. This was the case for accounts at five banks across
different Country Offices (‘CO’).
4. During our testing, differences in bank account numbers were noted from three bank
reconciliations (GL180090, GL180080, and GL168060) compared to the bank account listing as a
result of typos made on the bank reconciliations. The account numbers per Plan Inc. bank account
listing for these accounts, however, was correct.
5. During our testing, it was noted that two bank reconciliations (GL168010 and GL168110) had
incorrect local currencies input into the bank reconciliation in the currency field. This had no financial
impact on the bank reconciliations performed.
6. For two GL accounts (GL168120 and GL168129) differences amounting to €693,984 between the
denominated balance in bank reconciliation and the denominated balance per trial balance were
noted. Plan confirmed the amount pertains to the revaluation of currency and that the account should
not be reevaluated in local currency. This is a system error due to the wrong set up of the monthly
revaluation process for these two specific GL accounts.
Cause:
For the first point, Plan had acted on the request to close the bank account when the request had been
acknowledged but before it had been confirmed, and therefore removed the account from the cash
listing despite a formal confirmation letter from the bank not being received.
For the second, the root cause of this issue is the CO not following the process in relation to opening
bank accounts and appropriately informing Regional Hub (‘RH’) and Global Hub (‘GH’).
For points three and four, the revised bank account numbers were not updated on the bank account
listing which still contained the old account numbers; and for point five the CO had not picked up the
incorrect currency field noted or incorrect bank account number following review of the
reconciliation.
For the sixth point, two GL accounts had an incorrect variant set up causing differences between the
bank reconciliation and the trial balance.
Effect:
Classifying balances as closed creates risks over the completeness of the bank account listing. There is
a risk that a large number of accounts are classified as closed despite still being open or an account
with a material cash balance could be excluded from the cash listing.
Not identifying and reporting bank accounts on a timely basis to GH and bank account numbers
inaccurately reflected on the bank account listing or bank reconciliations creates risks over the
completeness of the bank account listing.
Per the Bank Secrecy Act, Plan is required through FBAR ( Foreign Bank and Financial Accounts, US
Federal Government) to report all non-US bank accounts to the US in March each year. FBAR then
performs ad hoc checks of various entities and if Plan is found not reporting a full list of active
accounts, they will receive penalty fines for not complying with US requirements.
Incorrect currencies or account numbers reflected on the bank reconciliations and bank fees not
included creates risk over the completeness and accuracy of bank reconciliations.
Additionally, the incorrect application of the variants creates the risk of inaccuracies performed on the
foreign currency translation of bank accounts.
Recommendation:
We recommend the following:
Bank accounts are not classified as closed until a formal closure letter from the bank is received.
The RHs perform timely monthly reviews to ensure the completeness of bank accounts and COs are
reminded of the process around opening and closing bank accounts and the required notifications to
RH and GH.
Management put in place a process whereby appropriate review of bank details is performed at a CO
level during the year end FBAR process as reliance is placed by GH on what is reported by the Country
Offices.
Management update the bank account listing to reflect updated bank account numbers.
Management ensure COs review the bank reconciliations for accuracy of financial and non-financial
data (such as account numbers).
Management ensure the correct set up of the monthly revaluation process for bank related GL
accounts.
Views of Responsible Officials and Management’s Corrective Action Plan :
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-004: Foreign exchange translation methodology (repeat of prior year finding 2022-004, 2021-005, 2020-006, 2019-006) (significant deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23, FY22, FY21, FY20 and FY19
Pass-through: All applicable
Criteria:
Accurate and reliable financial records of many kinds are necessary to meet ongoing financial
reporting and operational needs and requirements. The rate of exchange used throughout any given
month is the spot rate from the second to last working day of the prior month. This is not therefore the
‘the rate of exchange ruling at the date of the transaction’ in accordance with the Plan Inc. accounting
policies as stated in the financial statements.
Condition:
For all transactions, the impact of exchange rates takes place in the following stages:
At a transaction level
1. Translation from document currency (i.e. currency of income/expense per invoice) to local
currency at the time of initial recognition
2. Local currency to functional currency (Euro)
3. Translation to actual rate at date of settlement
4. Translation of outstanding amounts within the balance sheet at the period end rate
At the consolidation level
5. Functional currency to reporting currency (USD)
We note the following:
The monthly rate used for consolidation purposes is also the spot rate from the second to last day of
the previous month and not an appropriate average rate as required and we have noted an immaterial
misstatement relating to the translation of I&E into the reporting currency (USD).
As the foreign exchange methodology is unchanged from the prior year, the matter therefore still
remains open in FY23.
In FY23 management performed a retrospective analysis to assess the misstatement caused by using
the incorrect foreign exchange rate. We have assessed this analysis and confirmed the completeness,
inputs and mathematical accuracy thereof. We have confirmed there is an immaterial misstatement
arising as a result of the effect of using the incorrect foreign exchange rates for income and
expenditure.
Cause:
The rates used, as noted above, are a spot rate from the second to last day of the prior month, not a
transaction date rate or suitable weighted average, or another alternative. The current system does not
allow for the correct rate to be used.
Effect:
Foreign exchange translation methodology is currently not in accordance with accounting standards.
There are differences within the Plan Inc. financial statements that have been identified but not
corrected as a result of the foreign exchange translation methodology issues noted.
Recommendation:
As management plan, design and configure the new ERP system consideration should be given to the
need to input foreign exchange rates into the system on a daily basis to ensure compliance with the
accounting standards and Plan’s accounting policies.
Views of Responsible Officials and Management’s Corrective Action Plan:
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-003: Classification, completeness and accuracy of bank accounts (significant
deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23
Pass-through: All applicable
Criteria:
Accurate and reliable financial records, including listing of bank accounts and bank reconciliations,
are necessary to ensure that testing populations are complete, accurate and bank accounts are
correctly classified.
Condition:
Plan Inc. holds over 550 bank accounts between Global Hub, Plan Ltd and the Country Offices. The
following points were noted during the Plan Inc. financial statement audit:
1. From our testing performed over opening and closing bank accounts at the regional hub level, we
noted an account which was classified as closed prior to receiving a formal letter from the bank
confirming the closure. The account remains open with a balance of €36.
2. In the bank confirmation we independently received from ECO Bank Cameroon we noted two
additional bank account balances of €212k (immaterial and below de minimis reporting threshold)
which were not included in the general ledger.
3. During our testing, differences in bank account numbers were noted in several instances between
either bank confirmations / bank statements / bank reconciliations compared to the bank account
listing which reflected the old account numbers. This was the case for accounts at five banks across
different Country Offices (‘CO’).
4. During our testing, differences in bank account numbers were noted from three bank
reconciliations (GL180090, GL180080, and GL168060) compared to the bank account listing as a
result of typos made on the bank reconciliations. The account numbers per Plan Inc. bank account
listing for these accounts, however, was correct.
5. During our testing, it was noted that two bank reconciliations (GL168010 and GL168110) had
incorrect local currencies input into the bank reconciliation in the currency field. This had no financial
impact on the bank reconciliations performed.
6. For two GL accounts (GL168120 and GL168129) differences amounting to €693,984 between the
denominated balance in bank reconciliation and the denominated balance per trial balance were
noted. Plan confirmed the amount pertains to the revaluation of currency and that the account should
not be reevaluated in local currency. This is a system error due to the wrong set up of the monthly
revaluation process for these two specific GL accounts.
Cause:
For the first point, Plan had acted on the request to close the bank account when the request had been
acknowledged but before it had been confirmed, and therefore removed the account from the cash
listing despite a formal confirmation letter from the bank not being received.
For the second, the root cause of this issue is the CO not following the process in relation to opening
bank accounts and appropriately informing Regional Hub (‘RH’) and Global Hub (‘GH’).
For points three and four, the revised bank account numbers were not updated on the bank account
listing which still contained the old account numbers; and for point five the CO had not picked up the
incorrect currency field noted or incorrect bank account number following review of the
reconciliation.
For the sixth point, two GL accounts had an incorrect variant set up causing differences between the
bank reconciliation and the trial balance.
Effect:
Classifying balances as closed creates risks over the completeness of the bank account listing. There is
a risk that a large number of accounts are classified as closed despite still being open or an account
with a material cash balance could be excluded from the cash listing.
Not identifying and reporting bank accounts on a timely basis to GH and bank account numbers
inaccurately reflected on the bank account listing or bank reconciliations creates risks over the
completeness of the bank account listing.
Per the Bank Secrecy Act, Plan is required through FBAR ( Foreign Bank and Financial Accounts, US
Federal Government) to report all non-US bank accounts to the US in March each year. FBAR then
performs ad hoc checks of various entities and if Plan is found not reporting a full list of active
accounts, they will receive penalty fines for not complying with US requirements.
Incorrect currencies or account numbers reflected on the bank reconciliations and bank fees not
included creates risk over the completeness and accuracy of bank reconciliations.
Additionally, the incorrect application of the variants creates the risk of inaccuracies performed on the
foreign currency translation of bank accounts.
Recommendation:
We recommend the following:
Bank accounts are not classified as closed until a formal closure letter from the bank is received.
The RHs perform timely monthly reviews to ensure the completeness of bank accounts and COs are
reminded of the process around opening and closing bank accounts and the required notifications to
RH and GH.
Management put in place a process whereby appropriate review of bank details is performed at a CO
level during the year end FBAR process as reliance is placed by GH on what is reported by the Country
Offices.
Management update the bank account listing to reflect updated bank account numbers.
Management ensure COs review the bank reconciliations for accuracy of financial and non-financial
data (such as account numbers).
Management ensure the correct set up of the monthly revaluation process for bank related GL
accounts.
Views of Responsible Officials and Management’s Corrective Action Plan :
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-004: Foreign exchange translation methodology (repeat of prior year finding 2022-004, 2021-005, 2020-006, 2019-006) (significant deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23, FY22, FY21, FY20 and FY19
Pass-through: All applicable
Criteria:
Accurate and reliable financial records of many kinds are necessary to meet ongoing financial
reporting and operational needs and requirements. The rate of exchange used throughout any given
month is the spot rate from the second to last working day of the prior month. This is not therefore the
‘the rate of exchange ruling at the date of the transaction’ in accordance with the Plan Inc. accounting
policies as stated in the financial statements.
Condition:
For all transactions, the impact of exchange rates takes place in the following stages:
At a transaction level
1. Translation from document currency (i.e. currency of income/expense per invoice) to local
currency at the time of initial recognition
2. Local currency to functional currency (Euro)
3. Translation to actual rate at date of settlement
4. Translation of outstanding amounts within the balance sheet at the period end rate
At the consolidation level
5. Functional currency to reporting currency (USD)
We note the following:
The monthly rate used for consolidation purposes is also the spot rate from the second to last day of
the previous month and not an appropriate average rate as required and we have noted an immaterial
misstatement relating to the translation of I&E into the reporting currency (USD).
As the foreign exchange methodology is unchanged from the prior year, the matter therefore still
remains open in FY23.
In FY23 management performed a retrospective analysis to assess the misstatement caused by using
the incorrect foreign exchange rate. We have assessed this analysis and confirmed the completeness,
inputs and mathematical accuracy thereof. We have confirmed there is an immaterial misstatement
arising as a result of the effect of using the incorrect foreign exchange rates for income and
expenditure.
Cause:
The rates used, as noted above, are a spot rate from the second to last day of the prior month, not a
transaction date rate or suitable weighted average, or another alternative. The current system does not
allow for the correct rate to be used.
Effect:
Foreign exchange translation methodology is currently not in accordance with accounting standards.
There are differences within the Plan Inc. financial statements that have been identified but not
corrected as a result of the foreign exchange translation methodology issues noted.
Recommendation:
As management plan, design and configure the new ERP system consideration should be given to the
need to input foreign exchange rates into the system on a daily basis to ensure compliance with the
accounting standards and Plan’s accounting policies.
Views of Responsible Officials and Management’s Corrective Action Plan:
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-003: Classification, completeness and accuracy of bank accounts (significant
deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23
Pass-through: All applicable
Criteria:
Accurate and reliable financial records, including listing of bank accounts and bank reconciliations,
are necessary to ensure that testing populations are complete, accurate and bank accounts are
correctly classified.
Condition:
Plan Inc. holds over 550 bank accounts between Global Hub, Plan Ltd and the Country Offices. The
following points were noted during the Plan Inc. financial statement audit:
1. From our testing performed over opening and closing bank accounts at the regional hub level, we
noted an account which was classified as closed prior to receiving a formal letter from the bank
confirming the closure. The account remains open with a balance of €36.
2. In the bank confirmation we independently received from ECO Bank Cameroon we noted two
additional bank account balances of €212k (immaterial and below de minimis reporting threshold)
which were not included in the general ledger.
3. During our testing, differences in bank account numbers were noted in several instances between
either bank confirmations / bank statements / bank reconciliations compared to the bank account
listing which reflected the old account numbers. This was the case for accounts at five banks across
different Country Offices (‘CO’).
4. During our testing, differences in bank account numbers were noted from three bank
reconciliations (GL180090, GL180080, and GL168060) compared to the bank account listing as a
result of typos made on the bank reconciliations. The account numbers per Plan Inc. bank account
listing for these accounts, however, was correct.
5. During our testing, it was noted that two bank reconciliations (GL168010 and GL168110) had
incorrect local currencies input into the bank reconciliation in the currency field. This had no financial
impact on the bank reconciliations performed.
6. For two GL accounts (GL168120 and GL168129) differences amounting to €693,984 between the
denominated balance in bank reconciliation and the denominated balance per trial balance were
noted. Plan confirmed the amount pertains to the revaluation of currency and that the account should
not be reevaluated in local currency. This is a system error due to the wrong set up of the monthly
revaluation process for these two specific GL accounts.
Cause:
For the first point, Plan had acted on the request to close the bank account when the request had been
acknowledged but before it had been confirmed, and therefore removed the account from the cash
listing despite a formal confirmation letter from the bank not being received.
For the second, the root cause of this issue is the CO not following the process in relation to opening
bank accounts and appropriately informing Regional Hub (‘RH’) and Global Hub (‘GH’).
For points three and four, the revised bank account numbers were not updated on the bank account
listing which still contained the old account numbers; and for point five the CO had not picked up the
incorrect currency field noted or incorrect bank account number following review of the
reconciliation.
For the sixth point, two GL accounts had an incorrect variant set up causing differences between the
bank reconciliation and the trial balance.
Effect:
Classifying balances as closed creates risks over the completeness of the bank account listing. There is
a risk that a large number of accounts are classified as closed despite still being open or an account
with a material cash balance could be excluded from the cash listing.
Not identifying and reporting bank accounts on a timely basis to GH and bank account numbers
inaccurately reflected on the bank account listing or bank reconciliations creates risks over the
completeness of the bank account listing.
Per the Bank Secrecy Act, Plan is required through FBAR ( Foreign Bank and Financial Accounts, US
Federal Government) to report all non-US bank accounts to the US in March each year. FBAR then
performs ad hoc checks of various entities and if Plan is found not reporting a full list of active
accounts, they will receive penalty fines for not complying with US requirements.
Incorrect currencies or account numbers reflected on the bank reconciliations and bank fees not
included creates risk over the completeness and accuracy of bank reconciliations.
Additionally, the incorrect application of the variants creates the risk of inaccuracies performed on the
foreign currency translation of bank accounts.
Recommendation:
We recommend the following:
Bank accounts are not classified as closed until a formal closure letter from the bank is received.
The RHs perform timely monthly reviews to ensure the completeness of bank accounts and COs are
reminded of the process around opening and closing bank accounts and the required notifications to
RH and GH.
Management put in place a process whereby appropriate review of bank details is performed at a CO
level during the year end FBAR process as reliance is placed by GH on what is reported by the Country
Offices.
Management update the bank account listing to reflect updated bank account numbers.
Management ensure COs review the bank reconciliations for accuracy of financial and non-financial
data (such as account numbers).
Management ensure the correct set up of the monthly revaluation process for bank related GL
accounts.
Views of Responsible Officials and Management’s Corrective Action Plan :
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-004: Foreign exchange translation methodology (repeat of prior year finding 2022-004, 2021-005, 2020-006, 2019-006) (significant deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23, FY22, FY21, FY20 and FY19
Pass-through: All applicable
Criteria:
Accurate and reliable financial records of many kinds are necessary to meet ongoing financial
reporting and operational needs and requirements. The rate of exchange used throughout any given
month is the spot rate from the second to last working day of the prior month. This is not therefore the
‘the rate of exchange ruling at the date of the transaction’ in accordance with the Plan Inc. accounting
policies as stated in the financial statements.
Condition:
For all transactions, the impact of exchange rates takes place in the following stages:
At a transaction level
1. Translation from document currency (i.e. currency of income/expense per invoice) to local
currency at the time of initial recognition
2. Local currency to functional currency (Euro)
3. Translation to actual rate at date of settlement
4. Translation of outstanding amounts within the balance sheet at the period end rate
At the consolidation level
5. Functional currency to reporting currency (USD)
We note the following:
The monthly rate used for consolidation purposes is also the spot rate from the second to last day of
the previous month and not an appropriate average rate as required and we have noted an immaterial
misstatement relating to the translation of I&E into the reporting currency (USD).
As the foreign exchange methodology is unchanged from the prior year, the matter therefore still
remains open in FY23.
In FY23 management performed a retrospective analysis to assess the misstatement caused by using
the incorrect foreign exchange rate. We have assessed this analysis and confirmed the completeness,
inputs and mathematical accuracy thereof. We have confirmed there is an immaterial misstatement
arising as a result of the effect of using the incorrect foreign exchange rates for income and
expenditure.
Cause:
The rates used, as noted above, are a spot rate from the second to last day of the prior month, not a
transaction date rate or suitable weighted average, or another alternative. The current system does not
allow for the correct rate to be used.
Effect:
Foreign exchange translation methodology is currently not in accordance with accounting standards.
There are differences within the Plan Inc. financial statements that have been identified but not
corrected as a result of the foreign exchange translation methodology issues noted.
Recommendation:
As management plan, design and configure the new ERP system consideration should be given to the
need to input foreign exchange rates into the system on a daily basis to ensure compliance with the
accounting standards and Plan’s accounting policies.
Views of Responsible Officials and Management’s Corrective Action Plan:
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-003: Classification, completeness and accuracy of bank accounts (significant
deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23
Pass-through: All applicable
Criteria:
Accurate and reliable financial records, including listing of bank accounts and bank reconciliations,
are necessary to ensure that testing populations are complete, accurate and bank accounts are
correctly classified.
Condition:
Plan Inc. holds over 550 bank accounts between Global Hub, Plan Ltd and the Country Offices. The
following points were noted during the Plan Inc. financial statement audit:
1. From our testing performed over opening and closing bank accounts at the regional hub level, we
noted an account which was classified as closed prior to receiving a formal letter from the bank
confirming the closure. The account remains open with a balance of €36.
2. In the bank confirmation we independently received from ECO Bank Cameroon we noted two
additional bank account balances of €212k (immaterial and below de minimis reporting threshold)
which were not included in the general ledger.
3. During our testing, differences in bank account numbers were noted in several instances between
either bank confirmations / bank statements / bank reconciliations compared to the bank account
listing which reflected the old account numbers. This was the case for accounts at five banks across
different Country Offices (‘CO’).
4. During our testing, differences in bank account numbers were noted from three bank
reconciliations (GL180090, GL180080, and GL168060) compared to the bank account listing as a
result of typos made on the bank reconciliations. The account numbers per Plan Inc. bank account
listing for these accounts, however, was correct.
5. During our testing, it was noted that two bank reconciliations (GL168010 and GL168110) had
incorrect local currencies input into the bank reconciliation in the currency field. This had no financial
impact on the bank reconciliations performed.
6. For two GL accounts (GL168120 and GL168129) differences amounting to €693,984 between the
denominated balance in bank reconciliation and the denominated balance per trial balance were
noted. Plan confirmed the amount pertains to the revaluation of currency and that the account should
not be reevaluated in local currency. This is a system error due to the wrong set up of the monthly
revaluation process for these two specific GL accounts.
Cause:
For the first point, Plan had acted on the request to close the bank account when the request had been
acknowledged but before it had been confirmed, and therefore removed the account from the cash
listing despite a formal confirmation letter from the bank not being received.
For the second, the root cause of this issue is the CO not following the process in relation to opening
bank accounts and appropriately informing Regional Hub (‘RH’) and Global Hub (‘GH’).
For points three and four, the revised bank account numbers were not updated on the bank account
listing which still contained the old account numbers; and for point five the CO had not picked up the
incorrect currency field noted or incorrect bank account number following review of the
reconciliation.
For the sixth point, two GL accounts had an incorrect variant set up causing differences between the
bank reconciliation and the trial balance.
Effect:
Classifying balances as closed creates risks over the completeness of the bank account listing. There is
a risk that a large number of accounts are classified as closed despite still being open or an account
with a material cash balance could be excluded from the cash listing.
Not identifying and reporting bank accounts on a timely basis to GH and bank account numbers
inaccurately reflected on the bank account listing or bank reconciliations creates risks over the
completeness of the bank account listing.
Per the Bank Secrecy Act, Plan is required through FBAR ( Foreign Bank and Financial Accounts, US
Federal Government) to report all non-US bank accounts to the US in March each year. FBAR then
performs ad hoc checks of various entities and if Plan is found not reporting a full list of active
accounts, they will receive penalty fines for not complying with US requirements.
Incorrect currencies or account numbers reflected on the bank reconciliations and bank fees not
included creates risk over the completeness and accuracy of bank reconciliations.
Additionally, the incorrect application of the variants creates the risk of inaccuracies performed on the
foreign currency translation of bank accounts.
Recommendation:
We recommend the following:
Bank accounts are not classified as closed until a formal closure letter from the bank is received.
The RHs perform timely monthly reviews to ensure the completeness of bank accounts and COs are
reminded of the process around opening and closing bank accounts and the required notifications to
RH and GH.
Management put in place a process whereby appropriate review of bank details is performed at a CO
level during the year end FBAR process as reliance is placed by GH on what is reported by the Country
Offices.
Management update the bank account listing to reflect updated bank account numbers.
Management ensure COs review the bank reconciliations for accuracy of financial and non-financial
data (such as account numbers).
Management ensure the correct set up of the monthly revaluation process for bank related GL
accounts.
Views of Responsible Officials and Management’s Corrective Action Plan :
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-004: Foreign exchange translation methodology (repeat of prior year finding 2022-004, 2021-005, 2020-006, 2019-006) (significant deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23, FY22, FY21, FY20 and FY19
Pass-through: All applicable
Criteria:
Accurate and reliable financial records of many kinds are necessary to meet ongoing financial
reporting and operational needs and requirements. The rate of exchange used throughout any given
month is the spot rate from the second to last working day of the prior month. This is not therefore the
‘the rate of exchange ruling at the date of the transaction’ in accordance with the Plan Inc. accounting
policies as stated in the financial statements.
Condition:
For all transactions, the impact of exchange rates takes place in the following stages:
At a transaction level
1. Translation from document currency (i.e. currency of income/expense per invoice) to local
currency at the time of initial recognition
2. Local currency to functional currency (Euro)
3. Translation to actual rate at date of settlement
4. Translation of outstanding amounts within the balance sheet at the period end rate
At the consolidation level
5. Functional currency to reporting currency (USD)
We note the following:
The monthly rate used for consolidation purposes is also the spot rate from the second to last day of
the previous month and not an appropriate average rate as required and we have noted an immaterial
misstatement relating to the translation of I&E into the reporting currency (USD).
As the foreign exchange methodology is unchanged from the prior year, the matter therefore still
remains open in FY23.
In FY23 management performed a retrospective analysis to assess the misstatement caused by using
the incorrect foreign exchange rate. We have assessed this analysis and confirmed the completeness,
inputs and mathematical accuracy thereof. We have confirmed there is an immaterial misstatement
arising as a result of the effect of using the incorrect foreign exchange rates for income and
expenditure.
Cause:
The rates used, as noted above, are a spot rate from the second to last day of the prior month, not a
transaction date rate or suitable weighted average, or another alternative. The current system does not
allow for the correct rate to be used.
Effect:
Foreign exchange translation methodology is currently not in accordance with accounting standards.
There are differences within the Plan Inc. financial statements that have been identified but not
corrected as a result of the foreign exchange translation methodology issues noted.
Recommendation:
As management plan, design and configure the new ERP system consideration should be given to the
need to input foreign exchange rates into the system on a daily basis to ensure compliance with the
accounting standards and Plan’s accounting policies.
Views of Responsible Officials and Management’s Corrective Action Plan:
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-003: Classification, completeness and accuracy of bank accounts (significant
deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23
Pass-through: All applicable
Criteria:
Accurate and reliable financial records, including listing of bank accounts and bank reconciliations,
are necessary to ensure that testing populations are complete, accurate and bank accounts are
correctly classified.
Condition:
Plan Inc. holds over 550 bank accounts between Global Hub, Plan Ltd and the Country Offices. The
following points were noted during the Plan Inc. financial statement audit:
1. From our testing performed over opening and closing bank accounts at the regional hub level, we
noted an account which was classified as closed prior to receiving a formal letter from the bank
confirming the closure. The account remains open with a balance of €36.
2. In the bank confirmation we independently received from ECO Bank Cameroon we noted two
additional bank account balances of €212k (immaterial and below de minimis reporting threshold)
which were not included in the general ledger.
3. During our testing, differences in bank account numbers were noted in several instances between
either bank confirmations / bank statements / bank reconciliations compared to the bank account
listing which reflected the old account numbers. This was the case for accounts at five banks across
different Country Offices (‘CO’).
4. During our testing, differences in bank account numbers were noted from three bank
reconciliations (GL180090, GL180080, and GL168060) compared to the bank account listing as a
result of typos made on the bank reconciliations. The account numbers per Plan Inc. bank account
listing for these accounts, however, was correct.
5. During our testing, it was noted that two bank reconciliations (GL168010 and GL168110) had
incorrect local currencies input into the bank reconciliation in the currency field. This had no financial
impact on the bank reconciliations performed.
6. For two GL accounts (GL168120 and GL168129) differences amounting to €693,984 between the
denominated balance in bank reconciliation and the denominated balance per trial balance were
noted. Plan confirmed the amount pertains to the revaluation of currency and that the account should
not be reevaluated in local currency. This is a system error due to the wrong set up of the monthly
revaluation process for these two specific GL accounts.
Cause:
For the first point, Plan had acted on the request to close the bank account when the request had been
acknowledged but before it had been confirmed, and therefore removed the account from the cash
listing despite a formal confirmation letter from the bank not being received.
For the second, the root cause of this issue is the CO not following the process in relation to opening
bank accounts and appropriately informing Regional Hub (‘RH’) and Global Hub (‘GH’).
For points three and four, the revised bank account numbers were not updated on the bank account
listing which still contained the old account numbers; and for point five the CO had not picked up the
incorrect currency field noted or incorrect bank account number following review of the
reconciliation.
For the sixth point, two GL accounts had an incorrect variant set up causing differences between the
bank reconciliation and the trial balance.
Effect:
Classifying balances as closed creates risks over the completeness of the bank account listing. There is
a risk that a large number of accounts are classified as closed despite still being open or an account
with a material cash balance could be excluded from the cash listing.
Not identifying and reporting bank accounts on a timely basis to GH and bank account numbers
inaccurately reflected on the bank account listing or bank reconciliations creates risks over the
completeness of the bank account listing.
Per the Bank Secrecy Act, Plan is required through FBAR ( Foreign Bank and Financial Accounts, US
Federal Government) to report all non-US bank accounts to the US in March each year. FBAR then
performs ad hoc checks of various entities and if Plan is found not reporting a full list of active
accounts, they will receive penalty fines for not complying with US requirements.
Incorrect currencies or account numbers reflected on the bank reconciliations and bank fees not
included creates risk over the completeness and accuracy of bank reconciliations.
Additionally, the incorrect application of the variants creates the risk of inaccuracies performed on the
foreign currency translation of bank accounts.
Recommendation:
We recommend the following:
Bank accounts are not classified as closed until a formal closure letter from the bank is received.
The RHs perform timely monthly reviews to ensure the completeness of bank accounts and COs are
reminded of the process around opening and closing bank accounts and the required notifications to
RH and GH.
Management put in place a process whereby appropriate review of bank details is performed at a CO
level during the year end FBAR process as reliance is placed by GH on what is reported by the Country
Offices.
Management update the bank account listing to reflect updated bank account numbers.
Management ensure COs review the bank reconciliations for accuracy of financial and non-financial
data (such as account numbers).
Management ensure the correct set up of the monthly revaluation process for bank related GL
accounts.
Views of Responsible Officials and Management’s Corrective Action Plan :
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-004: Foreign exchange translation methodology (repeat of prior year finding 2022-004, 2021-005, 2020-006, 2019-006) (significant deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23, FY22, FY21, FY20 and FY19
Pass-through: All applicable
Criteria:
Accurate and reliable financial records of many kinds are necessary to meet ongoing financial
reporting and operational needs and requirements. The rate of exchange used throughout any given
month is the spot rate from the second to last working day of the prior month. This is not therefore the
‘the rate of exchange ruling at the date of the transaction’ in accordance with the Plan Inc. accounting
policies as stated in the financial statements.
Condition:
For all transactions, the impact of exchange rates takes place in the following stages:
At a transaction level
1. Translation from document currency (i.e. currency of income/expense per invoice) to local
currency at the time of initial recognition
2. Local currency to functional currency (Euro)
3. Translation to actual rate at date of settlement
4. Translation of outstanding amounts within the balance sheet at the period end rate
At the consolidation level
5. Functional currency to reporting currency (USD)
We note the following:
The monthly rate used for consolidation purposes is also the spot rate from the second to last day of
the previous month and not an appropriate average rate as required and we have noted an immaterial
misstatement relating to the translation of I&E into the reporting currency (USD).
As the foreign exchange methodology is unchanged from the prior year, the matter therefore still
remains open in FY23.
In FY23 management performed a retrospective analysis to assess the misstatement caused by using
the incorrect foreign exchange rate. We have assessed this analysis and confirmed the completeness,
inputs and mathematical accuracy thereof. We have confirmed there is an immaterial misstatement
arising as a result of the effect of using the incorrect foreign exchange rates for income and
expenditure.
Cause:
The rates used, as noted above, are a spot rate from the second to last day of the prior month, not a
transaction date rate or suitable weighted average, or another alternative. The current system does not
allow for the correct rate to be used.
Effect:
Foreign exchange translation methodology is currently not in accordance with accounting standards.
There are differences within the Plan Inc. financial statements that have been identified but not
corrected as a result of the foreign exchange translation methodology issues noted.
Recommendation:
As management plan, design and configure the new ERP system consideration should be given to the
need to input foreign exchange rates into the system on a daily basis to ensure compliance with the
accounting standards and Plan’s accounting policies.
Views of Responsible Officials and Management’s Corrective Action Plan:
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-006: Documentation needs to be maintained to justify the rationale for
sole-source arrangements
Federal Agency: United States Agency for International Development (USAID) for Nigeria OTL
Program: Nigeria OTL
Assistance Listing: 98.001 (Nigeria OTL)
Award #: 72062021CA00006 NGA100152 (Nigeria OTL)
Award year: FY23
Pass-through: Plan USA, Inc.
Criteria:
Under 2 CFR 200.320(c) vendors above a micro-purchase threshold (currently $165 for Nigeria OTL,
which is more restrictive than the threshold in the Uniform Guidance) require a competitive process
that includes soliciting multiple bids/quotes to justify best value. The Uniform Guidance requires
purchasing decisions to be documented, including sole source justification, as applicable.
Condition :
We identified five transactions totalling $6,096 with two vendors where long-term arrangements
(LTA) were in place for the two vendors but documentation was not retained to demonstrate that a
competitive bid process had been performed prior to entering into the LTA.
We identified four transactions totalling $5,183 with one vendor where an LTA was in place, but the
LTA was extended with the same vendor without management documenting their rationale for sole
sourcing this arrangement. The original LTA dates back to 2018 and multiple vendors were initially
considered and documentation retained to demonstrate the initial tender at this point. However,
documentation was not retained regarding subsequent considerations around maintaining this
supplier under a sole source arrangement.
Cause:
Plan’s accounting policy is silent on a re-tender process should Plan choose to continue to use the
same vendor and as such LTAs were extended without retaining documentation that is required in
such instances under the Uniform Guidance.
Effect:
This could lead to missing out on better prospective vendors that management could do business with.
There is also a possibility of management bias to continue using the same vendor.
Recommendation:
Management should put in place policies and procedures that require retaining documentation to
justify the rationale for purchasing decisions consistent with the Uniform Guidance. We suggest that
management performs a re-tendering process at the end of any LTA prior to extending the contract or
otherwise documents the rationale for maintaining these suppliers under a sole source arrangement.
Views of Responsible Officials and Management’s Corrective Action Plan:
Views of responsible officials and management’s corrective action plan are included at the end of this
report after the summary schedule of prior audit findings and status.
Ref 2023-003: Classification, completeness and accuracy of bank accounts (significant
deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23
Pass-through: All applicable
Criteria:
Accurate and reliable financial records, including listing of bank accounts and bank reconciliations,
are necessary to ensure that testing populations are complete, accurate and bank accounts are
correctly classified.
Condition:
Plan Inc. holds over 550 bank accounts between Global Hub, Plan Ltd and the Country Offices. The
following points were noted during the Plan Inc. financial statement audit:
1. From our testing performed over opening and closing bank accounts at the regional hub level, we
noted an account which was classified as closed prior to receiving a formal letter from the bank
confirming the closure. The account remains open with a balance of €36.
2. In the bank confirmation we independently received from ECO Bank Cameroon we noted two
additional bank account balances of €212k (immaterial and below de minimis reporting threshold)
which were not included in the general ledger.
3. During our testing, differences in bank account numbers were noted in several instances between
either bank confirmations / bank statements / bank reconciliations compared to the bank account
listing which reflected the old account numbers. This was the case for accounts at five banks across
different Country Offices (‘CO’).
4. During our testing, differences in bank account numbers were noted from three bank
reconciliations (GL180090, GL180080, and GL168060) compared to the bank account listing as a
result of typos made on the bank reconciliations. The account numbers per Plan Inc. bank account
listing for these accounts, however, was correct.
5. During our testing, it was noted that two bank reconciliations (GL168010 and GL168110) had
incorrect local currencies input into the bank reconciliation in the currency field. This had no financial
impact on the bank reconciliations performed.
6. For two GL accounts (GL168120 and GL168129) differences amounting to €693,984 between the
denominated balance in bank reconciliation and the denominated balance per trial balance were
noted. Plan confirmed the amount pertains to the revaluation of currency and that the account should
not be reevaluated in local currency. This is a system error due to the wrong set up of the monthly
revaluation process for these two specific GL accounts.
Cause:
For the first point, Plan had acted on the request to close the bank account when the request had been
acknowledged but before it had been confirmed, and therefore removed the account from the cash
listing despite a formal confirmation letter from the bank not being received.
For the second, the root cause of this issue is the CO not following the process in relation to opening
bank accounts and appropriately informing Regional Hub (‘RH’) and Global Hub (‘GH’).
For points three and four, the revised bank account numbers were not updated on the bank account
listing which still contained the old account numbers; and for point five the CO had not picked up the
incorrect currency field noted or incorrect bank account number following review of the
reconciliation.
For the sixth point, two GL accounts had an incorrect variant set up causing differences between the
bank reconciliation and the trial balance.
Effect:
Classifying balances as closed creates risks over the completeness of the bank account listing. There is
a risk that a large number of accounts are classified as closed despite still being open or an account
with a material cash balance could be excluded from the cash listing.
Not identifying and reporting bank accounts on a timely basis to GH and bank account numbers
inaccurately reflected on the bank account listing or bank reconciliations creates risks over the
completeness of the bank account listing.
Per the Bank Secrecy Act, Plan is required through FBAR ( Foreign Bank and Financial Accounts, US
Federal Government) to report all non-US bank accounts to the US in March each year. FBAR then
performs ad hoc checks of various entities and if Plan is found not reporting a full list of active
accounts, they will receive penalty fines for not complying with US requirements.
Incorrect currencies or account numbers reflected on the bank reconciliations and bank fees not
included creates risk over the completeness and accuracy of bank reconciliations.
Additionally, the incorrect application of the variants creates the risk of inaccuracies performed on the
foreign currency translation of bank accounts.
Recommendation:
We recommend the following:
Bank accounts are not classified as closed until a formal closure letter from the bank is received.
The RHs perform timely monthly reviews to ensure the completeness of bank accounts and COs are
reminded of the process around opening and closing bank accounts and the required notifications to
RH and GH.
Management put in place a process whereby appropriate review of bank details is performed at a CO
level during the year end FBAR process as reliance is placed by GH on what is reported by the Country
Offices.
Management update the bank account listing to reflect updated bank account numbers.
Management ensure COs review the bank reconciliations for accuracy of financial and non-financial
data (such as account numbers).
Management ensure the correct set up of the monthly revaluation process for bank related GL
accounts.
Views of Responsible Officials and Management’s Corrective Action Plan :
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-004: Foreign exchange translation methodology (repeat of prior year finding 2022-004, 2021-005, 2020-006, 2019-006) (significant deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23, FY22, FY21, FY20 and FY19
Pass-through: All applicable
Criteria:
Accurate and reliable financial records of many kinds are necessary to meet ongoing financial
reporting and operational needs and requirements. The rate of exchange used throughout any given
month is the spot rate from the second to last working day of the prior month. This is not therefore the
‘the rate of exchange ruling at the date of the transaction’ in accordance with the Plan Inc. accounting
policies as stated in the financial statements.
Condition:
For all transactions, the impact of exchange rates takes place in the following stages:
At a transaction level
1. Translation from document currency (i.e. currency of income/expense per invoice) to local
currency at the time of initial recognition
2. Local currency to functional currency (Euro)
3. Translation to actual rate at date of settlement
4. Translation of outstanding amounts within the balance sheet at the period end rate
At the consolidation level
5. Functional currency to reporting currency (USD)
We note the following:
The monthly rate used for consolidation purposes is also the spot rate from the second to last day of
the previous month and not an appropriate average rate as required and we have noted an immaterial
misstatement relating to the translation of I&E into the reporting currency (USD).
As the foreign exchange methodology is unchanged from the prior year, the matter therefore still
remains open in FY23.
In FY23 management performed a retrospective analysis to assess the misstatement caused by using
the incorrect foreign exchange rate. We have assessed this analysis and confirmed the completeness,
inputs and mathematical accuracy thereof. We have confirmed there is an immaterial misstatement
arising as a result of the effect of using the incorrect foreign exchange rates for income and
expenditure.
Cause:
The rates used, as noted above, are a spot rate from the second to last day of the prior month, not a
transaction date rate or suitable weighted average, or another alternative. The current system does not
allow for the correct rate to be used.
Effect:
Foreign exchange translation methodology is currently not in accordance with accounting standards.
There are differences within the Plan Inc. financial statements that have been identified but not
corrected as a result of the foreign exchange translation methodology issues noted.
Recommendation:
As management plan, design and configure the new ERP system consideration should be given to the
need to input foreign exchange rates into the system on a daily basis to ensure compliance with the
accounting standards and Plan’s accounting policies.
Views of Responsible Officials and Management’s Corrective Action Plan:
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-003: Classification, completeness and accuracy of bank accounts (significant
deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23
Pass-through: All applicable
Criteria:
Accurate and reliable financial records, including listing of bank accounts and bank reconciliations,
are necessary to ensure that testing populations are complete, accurate and bank accounts are
correctly classified.
Condition:
Plan Inc. holds over 550 bank accounts between Global Hub, Plan Ltd and the Country Offices. The
following points were noted during the Plan Inc. financial statement audit:
1. From our testing performed over opening and closing bank accounts at the regional hub level, we
noted an account which was classified as closed prior to receiving a formal letter from the bank
confirming the closure. The account remains open with a balance of €36.
2. In the bank confirmation we independently received from ECO Bank Cameroon we noted two
additional bank account balances of €212k (immaterial and below de minimis reporting threshold)
which were not included in the general ledger.
3. During our testing, differences in bank account numbers were noted in several instances between
either bank confirmations / bank statements / bank reconciliations compared to the bank account
listing which reflected the old account numbers. This was the case for accounts at five banks across
different Country Offices (‘CO’).
4. During our testing, differences in bank account numbers were noted from three bank
reconciliations (GL180090, GL180080, and GL168060) compared to the bank account listing as a
result of typos made on the bank reconciliations. The account numbers per Plan Inc. bank account
listing for these accounts, however, was correct.
5. During our testing, it was noted that two bank reconciliations (GL168010 and GL168110) had
incorrect local currencies input into the bank reconciliation in the currency field. This had no financial
impact on the bank reconciliations performed.
6. For two GL accounts (GL168120 and GL168129) differences amounting to €693,984 between the
denominated balance in bank reconciliation and the denominated balance per trial balance were
noted. Plan confirmed the amount pertains to the revaluation of currency and that the account should
not be reevaluated in local currency. This is a system error due to the wrong set up of the monthly
revaluation process for these two specific GL accounts.
Cause:
For the first point, Plan had acted on the request to close the bank account when the request had been
acknowledged but before it had been confirmed, and therefore removed the account from the cash
listing despite a formal confirmation letter from the bank not being received.
For the second, the root cause of this issue is the CO not following the process in relation to opening
bank accounts and appropriately informing Regional Hub (‘RH’) and Global Hub (‘GH’).
For points three and four, the revised bank account numbers were not updated on the bank account
listing which still contained the old account numbers; and for point five the CO had not picked up the
incorrect currency field noted or incorrect bank account number following review of the
reconciliation.
For the sixth point, two GL accounts had an incorrect variant set up causing differences between the
bank reconciliation and the trial balance.
Effect:
Classifying balances as closed creates risks over the completeness of the bank account listing. There is
a risk that a large number of accounts are classified as closed despite still being open or an account
with a material cash balance could be excluded from the cash listing.
Not identifying and reporting bank accounts on a timely basis to GH and bank account numbers
inaccurately reflected on the bank account listing or bank reconciliations creates risks over the
completeness of the bank account listing.
Per the Bank Secrecy Act, Plan is required through FBAR ( Foreign Bank and Financial Accounts, US
Federal Government) to report all non-US bank accounts to the US in March each year. FBAR then
performs ad hoc checks of various entities and if Plan is found not reporting a full list of active
accounts, they will receive penalty fines for not complying with US requirements.
Incorrect currencies or account numbers reflected on the bank reconciliations and bank fees not
included creates risk over the completeness and accuracy of bank reconciliations.
Additionally, the incorrect application of the variants creates the risk of inaccuracies performed on the
foreign currency translation of bank accounts.
Recommendation:
We recommend the following:
Bank accounts are not classified as closed until a formal closure letter from the bank is received.
The RHs perform timely monthly reviews to ensure the completeness of bank accounts and COs are
reminded of the process around opening and closing bank accounts and the required notifications to
RH and GH.
Management put in place a process whereby appropriate review of bank details is performed at a CO
level during the year end FBAR process as reliance is placed by GH on what is reported by the Country
Offices.
Management update the bank account listing to reflect updated bank account numbers.
Management ensure COs review the bank reconciliations for accuracy of financial and non-financial
data (such as account numbers).
Management ensure the correct set up of the monthly revaluation process for bank related GL
accounts.
Views of Responsible Officials and Management’s Corrective Action Plan :
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-004: Foreign exchange translation methodology (repeat of prior year finding 2022-004, 2021-005, 2020-006, 2019-006) (significant deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23, FY22, FY21, FY20 and FY19
Pass-through: All applicable
Criteria:
Accurate and reliable financial records of many kinds are necessary to meet ongoing financial
reporting and operational needs and requirements. The rate of exchange used throughout any given
month is the spot rate from the second to last working day of the prior month. This is not therefore the
‘the rate of exchange ruling at the date of the transaction’ in accordance with the Plan Inc. accounting
policies as stated in the financial statements.
Condition:
For all transactions, the impact of exchange rates takes place in the following stages:
At a transaction level
1. Translation from document currency (i.e. currency of income/expense per invoice) to local
currency at the time of initial recognition
2. Local currency to functional currency (Euro)
3. Translation to actual rate at date of settlement
4. Translation of outstanding amounts within the balance sheet at the period end rate
At the consolidation level
5. Functional currency to reporting currency (USD)
We note the following:
The monthly rate used for consolidation purposes is also the spot rate from the second to last day of
the previous month and not an appropriate average rate as required and we have noted an immaterial
misstatement relating to the translation of I&E into the reporting currency (USD).
As the foreign exchange methodology is unchanged from the prior year, the matter therefore still
remains open in FY23.
In FY23 management performed a retrospective analysis to assess the misstatement caused by using
the incorrect foreign exchange rate. We have assessed this analysis and confirmed the completeness,
inputs and mathematical accuracy thereof. We have confirmed there is an immaterial misstatement
arising as a result of the effect of using the incorrect foreign exchange rates for income and
expenditure.
Cause:
The rates used, as noted above, are a spot rate from the second to last day of the prior month, not a
transaction date rate or suitable weighted average, or another alternative. The current system does not
allow for the correct rate to be used.
Effect:
Foreign exchange translation methodology is currently not in accordance with accounting standards.
There are differences within the Plan Inc. financial statements that have been identified but not
corrected as a result of the foreign exchange translation methodology issues noted.
Recommendation:
As management plan, design and configure the new ERP system consideration should be given to the
need to input foreign exchange rates into the system on a daily basis to ensure compliance with the
accounting standards and Plan’s accounting policies.
Views of Responsible Officials and Management’s Corrective Action Plan:
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-007: Suspension and debarment checks should be performed prior to doing
business with certain vendors
Federal Agency: U.S. Department of State for Ethiopia South Sudanese Refugee Assistance V and VI;
United States Agency for International Development (USAID)
Program: Ethiopia: South Sudanese Refugee Assistance V and VI; Ethiopia: BHA Tigray Child
Protection
Assistance Listing: 19.517 (Ethiopia); 98.001 (Ethiopia)
Award #: SPRMCO21CA3181 ETH102315 (Ethiopia), SPRMCO22CA0199 ETH102389 (Ethiopia);
720BHA21GR00199 ETH102324
Award year: FY23
Pass-through: Plan USA, Inc.
Criteria:
Non-federal entities are prohibited from contracting with or making subawards under covered
transactions to parties that are suspended or debarred. When a non-federal entity enters into a
covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as
defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or
otherwise excluded from participating in the transaction. This verification may be accomplished by (1)
checking the System for Award Management (SAM) Exclusions maintained by the General Services
Administration, (2) collecting a certification from the entity, or (3) adding a clause or condition to the
covered transaction with that entity (2 CFR section 180.300).
Condition :
Suspension and debarment checks are performed centrally by the compliance team based at Global
Hub (‘GH’). The compliance team obtains new vendor data from the finance system SAP on a weekly
basis and has a policy to check all vendors regardless of dollar value. Suspension and debarment
checks are performed over this list on a weekly basis using a third party ‘Automated Screening
Manager’ (‘ASM’) tool. In instances of one-off payments, the Country Office (‘CO’) sends a request via
email to the compliance team at GH to perform the suspension and debarment check. The results of
the ASM checks are shared with the COs.
We identified four samples out of a population of 67 samples where the date of the ASM check was
after the date of the transaction with the vendor. Management was therefore unable to evidence that a
suspension and debarment check had been performed prior to the transaction taking place. The time
period between the transaction dates of our samples and the date of the ASM checks ranged from one
day to 11 months.
The combined total of the four transactions was $19,108 and they occurred in one region (Ethiopia).
Cause:
The Global Hub compliance team was not notified on a timely basis of the new vendors by the
Ethiopia Country Office and therefore did not perform the suspension and debarment checks prior to
the transactions taking place.
Effect:
Vendors not checked if suspended or debarred prior to doing business with them could lead to
non-compliance to Uniform Guidance requirement.
Recommendation:
Management should ensure that COs are communicating with new vendors on a timely basis to ensure
that all vendors are checked for suspension and debarment before they are engaged and transacted
with and documentation is maintained demonstrating this check was completed.
Views of Responsible Officials and Management’s Corrective Action Plan:
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-003: Classification, completeness and accuracy of bank accounts (significant
deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23
Pass-through: All applicable
Criteria:
Accurate and reliable financial records, including listing of bank accounts and bank reconciliations,
are necessary to ensure that testing populations are complete, accurate and bank accounts are
correctly classified.
Condition:
Plan Inc. holds over 550 bank accounts between Global Hub, Plan Ltd and the Country Offices. The
following points were noted during the Plan Inc. financial statement audit:
1. From our testing performed over opening and closing bank accounts at the regional hub level, we
noted an account which was classified as closed prior to receiving a formal letter from the bank
confirming the closure. The account remains open with a balance of €36.
2. In the bank confirmation we independently received from ECO Bank Cameroon we noted two
additional bank account balances of €212k (immaterial and below de minimis reporting threshold)
which were not included in the general ledger.
3. During our testing, differences in bank account numbers were noted in several instances between
either bank confirmations / bank statements / bank reconciliations compared to the bank account
listing which reflected the old account numbers. This was the case for accounts at five banks across
different Country Offices (‘CO’).
4. During our testing, differences in bank account numbers were noted from three bank
reconciliations (GL180090, GL180080, and GL168060) compared to the bank account listing as a
result of typos made on the bank reconciliations. The account numbers per Plan Inc. bank account
listing for these accounts, however, was correct.
5. During our testing, it was noted that two bank reconciliations (GL168010 and GL168110) had
incorrect local currencies input into the bank reconciliation in the currency field. This had no financial
impact on the bank reconciliations performed.
6. For two GL accounts (GL168120 and GL168129) differences amounting to €693,984 between the
denominated balance in bank reconciliation and the denominated balance per trial balance were
noted. Plan confirmed the amount pertains to the revaluation of currency and that the account should
not be reevaluated in local currency. This is a system error due to the wrong set up of the monthly
revaluation process for these two specific GL accounts.
Cause:
For the first point, Plan had acted on the request to close the bank account when the request had been
acknowledged but before it had been confirmed, and therefore removed the account from the cash
listing despite a formal confirmation letter from the bank not being received.
For the second, the root cause of this issue is the CO not following the process in relation to opening
bank accounts and appropriately informing Regional Hub (‘RH’) and Global Hub (‘GH’).
For points three and four, the revised bank account numbers were not updated on the bank account
listing which still contained the old account numbers; and for point five the CO had not picked up the
incorrect currency field noted or incorrect bank account number following review of the
reconciliation.
For the sixth point, two GL accounts had an incorrect variant set up causing differences between the
bank reconciliation and the trial balance.
Effect:
Classifying balances as closed creates risks over the completeness of the bank account listing. There is
a risk that a large number of accounts are classified as closed despite still being open or an account
with a material cash balance could be excluded from the cash listing.
Not identifying and reporting bank accounts on a timely basis to GH and bank account numbers
inaccurately reflected on the bank account listing or bank reconciliations creates risks over the
completeness of the bank account listing.
Per the Bank Secrecy Act, Plan is required through FBAR ( Foreign Bank and Financial Accounts, US
Federal Government) to report all non-US bank accounts to the US in March each year. FBAR then
performs ad hoc checks of various entities and if Plan is found not reporting a full list of active
accounts, they will receive penalty fines for not complying with US requirements.
Incorrect currencies or account numbers reflected on the bank reconciliations and bank fees not
included creates risk over the completeness and accuracy of bank reconciliations.
Additionally, the incorrect application of the variants creates the risk of inaccuracies performed on the
foreign currency translation of bank accounts.
Recommendation:
We recommend the following:
Bank accounts are not classified as closed until a formal closure letter from the bank is received.
The RHs perform timely monthly reviews to ensure the completeness of bank accounts and COs are
reminded of the process around opening and closing bank accounts and the required notifications to
RH and GH.
Management put in place a process whereby appropriate review of bank details is performed at a CO
level during the year end FBAR process as reliance is placed by GH on what is reported by the Country
Offices.
Management update the bank account listing to reflect updated bank account numbers.
Management ensure COs review the bank reconciliations for accuracy of financial and non-financial
data (such as account numbers).
Management ensure the correct set up of the monthly revaluation process for bank related GL
accounts.
Views of Responsible Officials and Management’s Corrective Action Plan :
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-004: Foreign exchange translation methodology (repeat of prior year finding 2022-004, 2021-005, 2020-006, 2019-006) (significant deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23, FY22, FY21, FY20 and FY19
Pass-through: All applicable
Criteria:
Accurate and reliable financial records of many kinds are necessary to meet ongoing financial
reporting and operational needs and requirements. The rate of exchange used throughout any given
month is the spot rate from the second to last working day of the prior month. This is not therefore the
‘the rate of exchange ruling at the date of the transaction’ in accordance with the Plan Inc. accounting
policies as stated in the financial statements.
Condition:
For all transactions, the impact of exchange rates takes place in the following stages:
At a transaction level
1. Translation from document currency (i.e. currency of income/expense per invoice) to local
currency at the time of initial recognition
2. Local currency to functional currency (Euro)
3. Translation to actual rate at date of settlement
4. Translation of outstanding amounts within the balance sheet at the period end rate
At the consolidation level
5. Functional currency to reporting currency (USD)
We note the following:
The monthly rate used for consolidation purposes is also the spot rate from the second to last day of
the previous month and not an appropriate average rate as required and we have noted an immaterial
misstatement relating to the translation of I&E into the reporting currency (USD).
As the foreign exchange methodology is unchanged from the prior year, the matter therefore still
remains open in FY23.
In FY23 management performed a retrospective analysis to assess the misstatement caused by using
the incorrect foreign exchange rate. We have assessed this analysis and confirmed the completeness,
inputs and mathematical accuracy thereof. We have confirmed there is an immaterial misstatement
arising as a result of the effect of using the incorrect foreign exchange rates for income and
expenditure.
Cause:
The rates used, as noted above, are a spot rate from the second to last day of the prior month, not a
transaction date rate or suitable weighted average, or another alternative. The current system does not
allow for the correct rate to be used.
Effect:
Foreign exchange translation methodology is currently not in accordance with accounting standards.
There are differences within the Plan Inc. financial statements that have been identified but not
corrected as a result of the foreign exchange translation methodology issues noted.
Recommendation:
As management plan, design and configure the new ERP system consideration should be given to the
need to input foreign exchange rates into the system on a daily basis to ensure compliance with the
accounting standards and Plan’s accounting policies.
Views of Responsible Officials and Management’s Corrective Action Plan:
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-003: Classification, completeness and accuracy of bank accounts (significant
deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23
Pass-through: All applicable
Criteria:
Accurate and reliable financial records, including listing of bank accounts and bank reconciliations,
are necessary to ensure that testing populations are complete, accurate and bank accounts are
correctly classified.
Condition:
Plan Inc. holds over 550 bank accounts between Global Hub, Plan Ltd and the Country Offices. The
following points were noted during the Plan Inc. financial statement audit:
1. From our testing performed over opening and closing bank accounts at the regional hub level, we
noted an account which was classified as closed prior to receiving a formal letter from the bank
confirming the closure. The account remains open with a balance of €36.
2. In the bank confirmation we independently received from ECO Bank Cameroon we noted two
additional bank account balances of €212k (immaterial and below de minimis reporting threshold)
which were not included in the general ledger.
3. During our testing, differences in bank account numbers were noted in several instances between
either bank confirmations / bank statements / bank reconciliations compared to the bank account
listing which reflected the old account numbers. This was the case for accounts at five banks across
different Country Offices (‘CO’).
4. During our testing, differences in bank account numbers were noted from three bank
reconciliations (GL180090, GL180080, and GL168060) compared to the bank account listing as a
result of typos made on the bank reconciliations. The account numbers per Plan Inc. bank account
listing for these accounts, however, was correct.
5. During our testing, it was noted that two bank reconciliations (GL168010 and GL168110) had
incorrect local currencies input into the bank reconciliation in the currency field. This had no financial
impact on the bank reconciliations performed.
6. For two GL accounts (GL168120 and GL168129) differences amounting to €693,984 between the
denominated balance in bank reconciliation and the denominated balance per trial balance were
noted. Plan confirmed the amount pertains to the revaluation of currency and that the account should
not be reevaluated in local currency. This is a system error due to the wrong set up of the monthly
revaluation process for these two specific GL accounts.
Cause:
For the first point, Plan had acted on the request to close the bank account when the request had been
acknowledged but before it had been confirmed, and therefore removed the account from the cash
listing despite a formal confirmation letter from the bank not being received.
For the second, the root cause of this issue is the CO not following the process in relation to opening
bank accounts and appropriately informing Regional Hub (‘RH’) and Global Hub (‘GH’).
For points three and four, the revised bank account numbers were not updated on the bank account
listing which still contained the old account numbers; and for point five the CO had not picked up the
incorrect currency field noted or incorrect bank account number following review of the
reconciliation.
For the sixth point, two GL accounts had an incorrect variant set up causing differences between the
bank reconciliation and the trial balance.
Effect:
Classifying balances as closed creates risks over the completeness of the bank account listing. There is
a risk that a large number of accounts are classified as closed despite still being open or an account
with a material cash balance could be excluded from the cash listing.
Not identifying and reporting bank accounts on a timely basis to GH and bank account numbers
inaccurately reflected on the bank account listing or bank reconciliations creates risks over the
completeness of the bank account listing.
Per the Bank Secrecy Act, Plan is required through FBAR ( Foreign Bank and Financial Accounts, US
Federal Government) to report all non-US bank accounts to the US in March each year. FBAR then
performs ad hoc checks of various entities and if Plan is found not reporting a full list of active
accounts, they will receive penalty fines for not complying with US requirements.
Incorrect currencies or account numbers reflected on the bank reconciliations and bank fees not
included creates risk over the completeness and accuracy of bank reconciliations.
Additionally, the incorrect application of the variants creates the risk of inaccuracies performed on the
foreign currency translation of bank accounts.
Recommendation:
We recommend the following:
Bank accounts are not classified as closed until a formal closure letter from the bank is received.
The RHs perform timely monthly reviews to ensure the completeness of bank accounts and COs are
reminded of the process around opening and closing bank accounts and the required notifications to
RH and GH.
Management put in place a process whereby appropriate review of bank details is performed at a CO
level during the year end FBAR process as reliance is placed by GH on what is reported by the Country
Offices.
Management update the bank account listing to reflect updated bank account numbers.
Management ensure COs review the bank reconciliations for accuracy of financial and non-financial
data (such as account numbers).
Management ensure the correct set up of the monthly revaluation process for bank related GL
accounts.
Views of Responsible Officials and Management’s Corrective Action Plan :
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-004: Foreign exchange translation methodology (repeat of prior year finding 2022-004, 2021-005, 2020-006, 2019-006) (significant deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23, FY22, FY21, FY20 and FY19
Pass-through: All applicable
Criteria:
Accurate and reliable financial records of many kinds are necessary to meet ongoing financial
reporting and operational needs and requirements. The rate of exchange used throughout any given
month is the spot rate from the second to last working day of the prior month. This is not therefore the
‘the rate of exchange ruling at the date of the transaction’ in accordance with the Plan Inc. accounting
policies as stated in the financial statements.
Condition:
For all transactions, the impact of exchange rates takes place in the following stages:
At a transaction level
1. Translation from document currency (i.e. currency of income/expense per invoice) to local
currency at the time of initial recognition
2. Local currency to functional currency (Euro)
3. Translation to actual rate at date of settlement
4. Translation of outstanding amounts within the balance sheet at the period end rate
At the consolidation level
5. Functional currency to reporting currency (USD)
We note the following:
The monthly rate used for consolidation purposes is also the spot rate from the second to last day of
the previous month and not an appropriate average rate as required and we have noted an immaterial
misstatement relating to the translation of I&E into the reporting currency (USD).
As the foreign exchange methodology is unchanged from the prior year, the matter therefore still
remains open in FY23.
In FY23 management performed a retrospective analysis to assess the misstatement caused by using
the incorrect foreign exchange rate. We have assessed this analysis and confirmed the completeness,
inputs and mathematical accuracy thereof. We have confirmed there is an immaterial misstatement
arising as a result of the effect of using the incorrect foreign exchange rates for income and
expenditure.
Cause:
The rates used, as noted above, are a spot rate from the second to last day of the prior month, not a
transaction date rate or suitable weighted average, or another alternative. The current system does not
allow for the correct rate to be used.
Effect:
Foreign exchange translation methodology is currently not in accordance with accounting standards.
There are differences within the Plan Inc. financial statements that have been identified but not
corrected as a result of the foreign exchange translation methodology issues noted.
Recommendation:
As management plan, design and configure the new ERP system consideration should be given to the
need to input foreign exchange rates into the system on a daily basis to ensure compliance with the
accounting standards and Plan’s accounting policies.
Views of Responsible Officials and Management’s Corrective Action Plan:
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-003: Classification, completeness and accuracy of bank accounts (significant
deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23
Pass-through: All applicable
Criteria:
Accurate and reliable financial records, including listing of bank accounts and bank reconciliations,
are necessary to ensure that testing populations are complete, accurate and bank accounts are
correctly classified.
Condition:
Plan Inc. holds over 550 bank accounts between Global Hub, Plan Ltd and the Country Offices. The
following points were noted during the Plan Inc. financial statement audit:
1. From our testing performed over opening and closing bank accounts at the regional hub level, we
noted an account which was classified as closed prior to receiving a formal letter from the bank
confirming the closure. The account remains open with a balance of €36.
2. In the bank confirmation we independently received from ECO Bank Cameroon we noted two
additional bank account balances of €212k (immaterial and below de minimis reporting threshold)
which were not included in the general ledger.
3. During our testing, differences in bank account numbers were noted in several instances between
either bank confirmations / bank statements / bank reconciliations compared to the bank account
listing which reflected the old account numbers. This was the case for accounts at five banks across
different Country Offices (‘CO’).
4. During our testing, differences in bank account numbers were noted from three bank
reconciliations (GL180090, GL180080, and GL168060) compared to the bank account listing as a
result of typos made on the bank reconciliations. The account numbers per Plan Inc. bank account
listing for these accounts, however, was correct.
5. During our testing, it was noted that two bank reconciliations (GL168010 and GL168110) had
incorrect local currencies input into the bank reconciliation in the currency field. This had no financial
impact on the bank reconciliations performed.
6. For two GL accounts (GL168120 and GL168129) differences amounting to €693,984 between the
denominated balance in bank reconciliation and the denominated balance per trial balance were
noted. Plan confirmed the amount pertains to the revaluation of currency and that the account should
not be reevaluated in local currency. This is a system error due to the wrong set up of the monthly
revaluation process for these two specific GL accounts.
Cause:
For the first point, Plan had acted on the request to close the bank account when the request had been
acknowledged but before it had been confirmed, and therefore removed the account from the cash
listing despite a formal confirmation letter from the bank not being received.
For the second, the root cause of this issue is the CO not following the process in relation to opening
bank accounts and appropriately informing Regional Hub (‘RH’) and Global Hub (‘GH’).
For points three and four, the revised bank account numbers were not updated on the bank account
listing which still contained the old account numbers; and for point five the CO had not picked up the
incorrect currency field noted or incorrect bank account number following review of the
reconciliation.
For the sixth point, two GL accounts had an incorrect variant set up causing differences between the
bank reconciliation and the trial balance.
Effect:
Classifying balances as closed creates risks over the completeness of the bank account listing. There is
a risk that a large number of accounts are classified as closed despite still being open or an account
with a material cash balance could be excluded from the cash listing.
Not identifying and reporting bank accounts on a timely basis to GH and bank account numbers
inaccurately reflected on the bank account listing or bank reconciliations creates risks over the
completeness of the bank account listing.
Per the Bank Secrecy Act, Plan is required through FBAR ( Foreign Bank and Financial Accounts, US
Federal Government) to report all non-US bank accounts to the US in March each year. FBAR then
performs ad hoc checks of various entities and if Plan is found not reporting a full list of active
accounts, they will receive penalty fines for not complying with US requirements.
Incorrect currencies or account numbers reflected on the bank reconciliations and bank fees not
included creates risk over the completeness and accuracy of bank reconciliations.
Additionally, the incorrect application of the variants creates the risk of inaccuracies performed on the
foreign currency translation of bank accounts.
Recommendation:
We recommend the following:
Bank accounts are not classified as closed until a formal closure letter from the bank is received.
The RHs perform timely monthly reviews to ensure the completeness of bank accounts and COs are
reminded of the process around opening and closing bank accounts and the required notifications to
RH and GH.
Management put in place a process whereby appropriate review of bank details is performed at a CO
level during the year end FBAR process as reliance is placed by GH on what is reported by the Country
Offices.
Management update the bank account listing to reflect updated bank account numbers.
Management ensure COs review the bank reconciliations for accuracy of financial and non-financial
data (such as account numbers).
Management ensure the correct set up of the monthly revaluation process for bank related GL
accounts.
Views of Responsible Officials and Management’s Corrective Action Plan :
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-004: Foreign exchange translation methodology (repeat of prior year finding 2022-004, 2021-005, 2020-006, 2019-006) (significant deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23, FY22, FY21, FY20 and FY19
Pass-through: All applicable
Criteria:
Accurate and reliable financial records of many kinds are necessary to meet ongoing financial
reporting and operational needs and requirements. The rate of exchange used throughout any given
month is the spot rate from the second to last working day of the prior month. This is not therefore the
‘the rate of exchange ruling at the date of the transaction’ in accordance with the Plan Inc. accounting
policies as stated in the financial statements.
Condition:
For all transactions, the impact of exchange rates takes place in the following stages:
At a transaction level
1. Translation from document currency (i.e. currency of income/expense per invoice) to local
currency at the time of initial recognition
2. Local currency to functional currency (Euro)
3. Translation to actual rate at date of settlement
4. Translation of outstanding amounts within the balance sheet at the period end rate
At the consolidation level
5. Functional currency to reporting currency (USD)
We note the following:
The monthly rate used for consolidation purposes is also the spot rate from the second to last day of
the previous month and not an appropriate average rate as required and we have noted an immaterial
misstatement relating to the translation of I&E into the reporting currency (USD).
As the foreign exchange methodology is unchanged from the prior year, the matter therefore still
remains open in FY23.
In FY23 management performed a retrospective analysis to assess the misstatement caused by using
the incorrect foreign exchange rate. We have assessed this analysis and confirmed the completeness,
inputs and mathematical accuracy thereof. We have confirmed there is an immaterial misstatement
arising as a result of the effect of using the incorrect foreign exchange rates for income and
expenditure.
Cause:
The rates used, as noted above, are a spot rate from the second to last day of the prior month, not a
transaction date rate or suitable weighted average, or another alternative. The current system does not
allow for the correct rate to be used.
Effect:
Foreign exchange translation methodology is currently not in accordance with accounting standards.
There are differences within the Plan Inc. financial statements that have been identified but not
corrected as a result of the foreign exchange translation methodology issues noted.
Recommendation:
As management plan, design and configure the new ERP system consideration should be given to the
need to input foreign exchange rates into the system on a daily basis to ensure compliance with the
accounting standards and Plan’s accounting policies.
Views of Responsible Officials and Management’s Corrective Action Plan:
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-003: Classification, completeness and accuracy of bank accounts (significant
deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23
Pass-through: All applicable
Criteria:
Accurate and reliable financial records, including listing of bank accounts and bank reconciliations,
are necessary to ensure that testing populations are complete, accurate and bank accounts are
correctly classified.
Condition:
Plan Inc. holds over 550 bank accounts between Global Hub, Plan Ltd and the Country Offices. The
following points were noted during the Plan Inc. financial statement audit:
1. From our testing performed over opening and closing bank accounts at the regional hub level, we
noted an account which was classified as closed prior to receiving a formal letter from the bank
confirming the closure. The account remains open with a balance of €36.
2. In the bank confirmation we independently received from ECO Bank Cameroon we noted two
additional bank account balances of €212k (immaterial and below de minimis reporting threshold)
which were not included in the general ledger.
3. During our testing, differences in bank account numbers were noted in several instances between
either bank confirmations / bank statements / bank reconciliations compared to the bank account
listing which reflected the old account numbers. This was the case for accounts at five banks across
different Country Offices (‘CO’).
4. During our testing, differences in bank account numbers were noted from three bank
reconciliations (GL180090, GL180080, and GL168060) compared to the bank account listing as a
result of typos made on the bank reconciliations. The account numbers per Plan Inc. bank account
listing for these accounts, however, was correct.
5. During our testing, it was noted that two bank reconciliations (GL168010 and GL168110) had
incorrect local currencies input into the bank reconciliation in the currency field. This had no financial
impact on the bank reconciliations performed.
6. For two GL accounts (GL168120 and GL168129) differences amounting to €693,984 between the
denominated balance in bank reconciliation and the denominated balance per trial balance were
noted. Plan confirmed the amount pertains to the revaluation of currency and that the account should
not be reevaluated in local currency. This is a system error due to the wrong set up of the monthly
revaluation process for these two specific GL accounts.
Cause:
For the first point, Plan had acted on the request to close the bank account when the request had been
acknowledged but before it had been confirmed, and therefore removed the account from the cash
listing despite a formal confirmation letter from the bank not being received.
For the second, the root cause of this issue is the CO not following the process in relation to opening
bank accounts and appropriately informing Regional Hub (‘RH’) and Global Hub (‘GH’).
For points three and four, the revised bank account numbers were not updated on the bank account
listing which still contained the old account numbers; and for point five the CO had not picked up the
incorrect currency field noted or incorrect bank account number following review of the
reconciliation.
For the sixth point, two GL accounts had an incorrect variant set up causing differences between the
bank reconciliation and the trial balance.
Effect:
Classifying balances as closed creates risks over the completeness of the bank account listing. There is
a risk that a large number of accounts are classified as closed despite still being open or an account
with a material cash balance could be excluded from the cash listing.
Not identifying and reporting bank accounts on a timely basis to GH and bank account numbers
inaccurately reflected on the bank account listing or bank reconciliations creates risks over the
completeness of the bank account listing.
Per the Bank Secrecy Act, Plan is required through FBAR ( Foreign Bank and Financial Accounts, US
Federal Government) to report all non-US bank accounts to the US in March each year. FBAR then
performs ad hoc checks of various entities and if Plan is found not reporting a full list of active
accounts, they will receive penalty fines for not complying with US requirements.
Incorrect currencies or account numbers reflected on the bank reconciliations and bank fees not
included creates risk over the completeness and accuracy of bank reconciliations.
Additionally, the incorrect application of the variants creates the risk of inaccuracies performed on the
foreign currency translation of bank accounts.
Recommendation:
We recommend the following:
Bank accounts are not classified as closed until a formal closure letter from the bank is received.
The RHs perform timely monthly reviews to ensure the completeness of bank accounts and COs are
reminded of the process around opening and closing bank accounts and the required notifications to
RH and GH.
Management put in place a process whereby appropriate review of bank details is performed at a CO
level during the year end FBAR process as reliance is placed by GH on what is reported by the Country
Offices.
Management update the bank account listing to reflect updated bank account numbers.
Management ensure COs review the bank reconciliations for accuracy of financial and non-financial
data (such as account numbers).
Management ensure the correct set up of the monthly revaluation process for bank related GL
accounts.
Views of Responsible Officials and Management’s Corrective Action Plan :
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-004: Foreign exchange translation methodology (repeat of prior year finding 2022-004, 2021-005, 2020-006, 2019-006) (significant deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23, FY22, FY21, FY20 and FY19
Pass-through: All applicable
Criteria:
Accurate and reliable financial records of many kinds are necessary to meet ongoing financial
reporting and operational needs and requirements. The rate of exchange used throughout any given
month is the spot rate from the second to last working day of the prior month. This is not therefore the
‘the rate of exchange ruling at the date of the transaction’ in accordance with the Plan Inc. accounting
policies as stated in the financial statements.
Condition:
For all transactions, the impact of exchange rates takes place in the following stages:
At a transaction level
1. Translation from document currency (i.e. currency of income/expense per invoice) to local
currency at the time of initial recognition
2. Local currency to functional currency (Euro)
3. Translation to actual rate at date of settlement
4. Translation of outstanding amounts within the balance sheet at the period end rate
At the consolidation level
5. Functional currency to reporting currency (USD)
We note the following:
The monthly rate used for consolidation purposes is also the spot rate from the second to last day of
the previous month and not an appropriate average rate as required and we have noted an immaterial
misstatement relating to the translation of I&E into the reporting currency (USD).
As the foreign exchange methodology is unchanged from the prior year, the matter therefore still
remains open in FY23.
In FY23 management performed a retrospective analysis to assess the misstatement caused by using
the incorrect foreign exchange rate. We have assessed this analysis and confirmed the completeness,
inputs and mathematical accuracy thereof. We have confirmed there is an immaterial misstatement
arising as a result of the effect of using the incorrect foreign exchange rates for income and
expenditure.
Cause:
The rates used, as noted above, are a spot rate from the second to last day of the prior month, not a
transaction date rate or suitable weighted average, or another alternative. The current system does not
allow for the correct rate to be used.
Effect:
Foreign exchange translation methodology is currently not in accordance with accounting standards.
There are differences within the Plan Inc. financial statements that have been identified but not
corrected as a result of the foreign exchange translation methodology issues noted.
Recommendation:
As management plan, design and configure the new ERP system consideration should be given to the
need to input foreign exchange rates into the system on a daily basis to ensure compliance with the
accounting standards and Plan’s accounting policies.
Views of Responsible Officials and Management’s Corrective Action Plan:
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-003: Classification, completeness and accuracy of bank accounts (significant
deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23
Pass-through: All applicable
Criteria:
Accurate and reliable financial records, including listing of bank accounts and bank reconciliations,
are necessary to ensure that testing populations are complete, accurate and bank accounts are
correctly classified.
Condition:
Plan Inc. holds over 550 bank accounts between Global Hub, Plan Ltd and the Country Offices. The
following points were noted during the Plan Inc. financial statement audit:
1. From our testing performed over opening and closing bank accounts at the regional hub level, we
noted an account which was classified as closed prior to receiving a formal letter from the bank
confirming the closure. The account remains open with a balance of €36.
2. In the bank confirmation we independently received from ECO Bank Cameroon we noted two
additional bank account balances of €212k (immaterial and below de minimis reporting threshold)
which were not included in the general ledger.
3. During our testing, differences in bank account numbers were noted in several instances between
either bank confirmations / bank statements / bank reconciliations compared to the bank account
listing which reflected the old account numbers. This was the case for accounts at five banks across
different Country Offices (‘CO’).
4. During our testing, differences in bank account numbers were noted from three bank
reconciliations (GL180090, GL180080, and GL168060) compared to the bank account listing as a
result of typos made on the bank reconciliations. The account numbers per Plan Inc. bank account
listing for these accounts, however, was correct.
5. During our testing, it was noted that two bank reconciliations (GL168010 and GL168110) had
incorrect local currencies input into the bank reconciliation in the currency field. This had no financial
impact on the bank reconciliations performed.
6. For two GL accounts (GL168120 and GL168129) differences amounting to €693,984 between the
denominated balance in bank reconciliation and the denominated balance per trial balance were
noted. Plan confirmed the amount pertains to the revaluation of currency and that the account should
not be reevaluated in local currency. This is a system error due to the wrong set up of the monthly
revaluation process for these two specific GL accounts.
Cause:
For the first point, Plan had acted on the request to close the bank account when the request had been
acknowledged but before it had been confirmed, and therefore removed the account from the cash
listing despite a formal confirmation letter from the bank not being received.
For the second, the root cause of this issue is the CO not following the process in relation to opening
bank accounts and appropriately informing Regional Hub (‘RH’) and Global Hub (‘GH’).
For points three and four, the revised bank account numbers were not updated on the bank account
listing which still contained the old account numbers; and for point five the CO had not picked up the
incorrect currency field noted or incorrect bank account number following review of the
reconciliation.
For the sixth point, two GL accounts had an incorrect variant set up causing differences between the
bank reconciliation and the trial balance.
Effect:
Classifying balances as closed creates risks over the completeness of the bank account listing. There is
a risk that a large number of accounts are classified as closed despite still being open or an account
with a material cash balance could be excluded from the cash listing.
Not identifying and reporting bank accounts on a timely basis to GH and bank account numbers
inaccurately reflected on the bank account listing or bank reconciliations creates risks over the
completeness of the bank account listing.
Per the Bank Secrecy Act, Plan is required through FBAR ( Foreign Bank and Financial Accounts, US
Federal Government) to report all non-US bank accounts to the US in March each year. FBAR then
performs ad hoc checks of various entities and if Plan is found not reporting a full list of active
accounts, they will receive penalty fines for not complying with US requirements.
Incorrect currencies or account numbers reflected on the bank reconciliations and bank fees not
included creates risk over the completeness and accuracy of bank reconciliations.
Additionally, the incorrect application of the variants creates the risk of inaccuracies performed on the
foreign currency translation of bank accounts.
Recommendation:
We recommend the following:
Bank accounts are not classified as closed until a formal closure letter from the bank is received.
The RHs perform timely monthly reviews to ensure the completeness of bank accounts and COs are
reminded of the process around opening and closing bank accounts and the required notifications to
RH and GH.
Management put in place a process whereby appropriate review of bank details is performed at a CO
level during the year end FBAR process as reliance is placed by GH on what is reported by the Country
Offices.
Management update the bank account listing to reflect updated bank account numbers.
Management ensure COs review the bank reconciliations for accuracy of financial and non-financial
data (such as account numbers).
Management ensure the correct set up of the monthly revaluation process for bank related GL
accounts.
Views of Responsible Officials and Management’s Corrective Action Plan :
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-004: Foreign exchange translation methodology (repeat of prior year finding 2022-004, 2021-005, 2020-006, 2019-006) (significant deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23, FY22, FY21, FY20 and FY19
Pass-through: All applicable
Criteria:
Accurate and reliable financial records of many kinds are necessary to meet ongoing financial
reporting and operational needs and requirements. The rate of exchange used throughout any given
month is the spot rate from the second to last working day of the prior month. This is not therefore the
‘the rate of exchange ruling at the date of the transaction’ in accordance with the Plan Inc. accounting
policies as stated in the financial statements.
Condition:
For all transactions, the impact of exchange rates takes place in the following stages:
At a transaction level
1. Translation from document currency (i.e. currency of income/expense per invoice) to local
currency at the time of initial recognition
2. Local currency to functional currency (Euro)
3. Translation to actual rate at date of settlement
4. Translation of outstanding amounts within the balance sheet at the period end rate
At the consolidation level
5. Functional currency to reporting currency (USD)
We note the following:
The monthly rate used for consolidation purposes is also the spot rate from the second to last day of
the previous month and not an appropriate average rate as required and we have noted an immaterial
misstatement relating to the translation of I&E into the reporting currency (USD).
As the foreign exchange methodology is unchanged from the prior year, the matter therefore still
remains open in FY23.
In FY23 management performed a retrospective analysis to assess the misstatement caused by using
the incorrect foreign exchange rate. We have assessed this analysis and confirmed the completeness,
inputs and mathematical accuracy thereof. We have confirmed there is an immaterial misstatement
arising as a result of the effect of using the incorrect foreign exchange rates for income and
expenditure.
Cause:
The rates used, as noted above, are a spot rate from the second to last day of the prior month, not a
transaction date rate or suitable weighted average, or another alternative. The current system does not
allow for the correct rate to be used.
Effect:
Foreign exchange translation methodology is currently not in accordance with accounting standards.
There are differences within the Plan Inc. financial statements that have been identified but not
corrected as a result of the foreign exchange translation methodology issues noted.
Recommendation:
As management plan, design and configure the new ERP system consideration should be given to the
need to input foreign exchange rates into the system on a daily basis to ensure compliance with the
accounting standards and Plan’s accounting policies.
Views of Responsible Officials and Management’s Corrective Action Plan:
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-003: Classification, completeness and accuracy of bank accounts (significant
deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23
Pass-through: All applicable
Criteria:
Accurate and reliable financial records, including listing of bank accounts and bank reconciliations,
are necessary to ensure that testing populations are complete, accurate and bank accounts are
correctly classified.
Condition:
Plan Inc. holds over 550 bank accounts between Global Hub, Plan Ltd and the Country Offices. The
following points were noted during the Plan Inc. financial statement audit:
1. From our testing performed over opening and closing bank accounts at the regional hub level, we
noted an account which was classified as closed prior to receiving a formal letter from the bank
confirming the closure. The account remains open with a balance of €36.
2. In the bank confirmation we independently received from ECO Bank Cameroon we noted two
additional bank account balances of €212k (immaterial and below de minimis reporting threshold)
which were not included in the general ledger.
3. During our testing, differences in bank account numbers were noted in several instances between
either bank confirmations / bank statements / bank reconciliations compared to the bank account
listing which reflected the old account numbers. This was the case for accounts at five banks across
different Country Offices (‘CO’).
4. During our testing, differences in bank account numbers were noted from three bank
reconciliations (GL180090, GL180080, and GL168060) compared to the bank account listing as a
result of typos made on the bank reconciliations. The account numbers per Plan Inc. bank account
listing for these accounts, however, was correct.
5. During our testing, it was noted that two bank reconciliations (GL168010 and GL168110) had
incorrect local currencies input into the bank reconciliation in the currency field. This had no financial
impact on the bank reconciliations performed.
6. For two GL accounts (GL168120 and GL168129) differences amounting to €693,984 between the
denominated balance in bank reconciliation and the denominated balance per trial balance were
noted. Plan confirmed the amount pertains to the revaluation of currency and that the account should
not be reevaluated in local currency. This is a system error due to the wrong set up of the monthly
revaluation process for these two specific GL accounts.
Cause:
For the first point, Plan had acted on the request to close the bank account when the request had been
acknowledged but before it had been confirmed, and therefore removed the account from the cash
listing despite a formal confirmation letter from the bank not being received.
For the second, the root cause of this issue is the CO not following the process in relation to opening
bank accounts and appropriately informing Regional Hub (‘RH’) and Global Hub (‘GH’).
For points three and four, the revised bank account numbers were not updated on the bank account
listing which still contained the old account numbers; and for point five the CO had not picked up the
incorrect currency field noted or incorrect bank account number following review of the
reconciliation.
For the sixth point, two GL accounts had an incorrect variant set up causing differences between the
bank reconciliation and the trial balance.
Effect:
Classifying balances as closed creates risks over the completeness of the bank account listing. There is
a risk that a large number of accounts are classified as closed despite still being open or an account
with a material cash balance could be excluded from the cash listing.
Not identifying and reporting bank accounts on a timely basis to GH and bank account numbers
inaccurately reflected on the bank account listing or bank reconciliations creates risks over the
completeness of the bank account listing.
Per the Bank Secrecy Act, Plan is required through FBAR ( Foreign Bank and Financial Accounts, US
Federal Government) to report all non-US bank accounts to the US in March each year. FBAR then
performs ad hoc checks of various entities and if Plan is found not reporting a full list of active
accounts, they will receive penalty fines for not complying with US requirements.
Incorrect currencies or account numbers reflected on the bank reconciliations and bank fees not
included creates risk over the completeness and accuracy of bank reconciliations.
Additionally, the incorrect application of the variants creates the risk of inaccuracies performed on the
foreign currency translation of bank accounts.
Recommendation:
We recommend the following:
Bank accounts are not classified as closed until a formal closure letter from the bank is received.
The RHs perform timely monthly reviews to ensure the completeness of bank accounts and COs are
reminded of the process around opening and closing bank accounts and the required notifications to
RH and GH.
Management put in place a process whereby appropriate review of bank details is performed at a CO
level during the year end FBAR process as reliance is placed by GH on what is reported by the Country
Offices.
Management update the bank account listing to reflect updated bank account numbers.
Management ensure COs review the bank reconciliations for accuracy of financial and non-financial
data (such as account numbers).
Management ensure the correct set up of the monthly revaluation process for bank related GL
accounts.
Views of Responsible Officials and Management’s Corrective Action Plan :
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-004: Foreign exchange translation methodology (repeat of prior year finding 2022-004, 2021-005, 2020-006, 2019-006) (significant deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23, FY22, FY21, FY20 and FY19
Pass-through: All applicable
Criteria:
Accurate and reliable financial records of many kinds are necessary to meet ongoing financial
reporting and operational needs and requirements. The rate of exchange used throughout any given
month is the spot rate from the second to last working day of the prior month. This is not therefore the
‘the rate of exchange ruling at the date of the transaction’ in accordance with the Plan Inc. accounting
policies as stated in the financial statements.
Condition:
For all transactions, the impact of exchange rates takes place in the following stages:
At a transaction level
1. Translation from document currency (i.e. currency of income/expense per invoice) to local
currency at the time of initial recognition
2. Local currency to functional currency (Euro)
3. Translation to actual rate at date of settlement
4. Translation of outstanding amounts within the balance sheet at the period end rate
At the consolidation level
5. Functional currency to reporting currency (USD)
We note the following:
The monthly rate used for consolidation purposes is also the spot rate from the second to last day of
the previous month and not an appropriate average rate as required and we have noted an immaterial
misstatement relating to the translation of I&E into the reporting currency (USD).
As the foreign exchange methodology is unchanged from the prior year, the matter therefore still
remains open in FY23.
In FY23 management performed a retrospective analysis to assess the misstatement caused by using
the incorrect foreign exchange rate. We have assessed this analysis and confirmed the completeness,
inputs and mathematical accuracy thereof. We have confirmed there is an immaterial misstatement
arising as a result of the effect of using the incorrect foreign exchange rates for income and
expenditure.
Cause:
The rates used, as noted above, are a spot rate from the second to last day of the prior month, not a
transaction date rate or suitable weighted average, or another alternative. The current system does not
allow for the correct rate to be used.
Effect:
Foreign exchange translation methodology is currently not in accordance with accounting standards.
There are differences within the Plan Inc. financial statements that have been identified but not
corrected as a result of the foreign exchange translation methodology issues noted.
Recommendation:
As management plan, design and configure the new ERP system consideration should be given to the
need to input foreign exchange rates into the system on a daily basis to ensure compliance with the
accounting standards and Plan’s accounting policies.
Views of Responsible Officials and Management’s Corrective Action Plan:
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-003: Classification, completeness and accuracy of bank accounts (significant
deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23
Pass-through: All applicable
Criteria:
Accurate and reliable financial records, including listing of bank accounts and bank reconciliations,
are necessary to ensure that testing populations are complete, accurate and bank accounts are
correctly classified.
Condition:
Plan Inc. holds over 550 bank accounts between Global Hub, Plan Ltd and the Country Offices. The
following points were noted during the Plan Inc. financial statement audit:
1. From our testing performed over opening and closing bank accounts at the regional hub level, we
noted an account which was classified as closed prior to receiving a formal letter from the bank
confirming the closure. The account remains open with a balance of €36.
2. In the bank confirmation we independently received from ECO Bank Cameroon we noted two
additional bank account balances of €212k (immaterial and below de minimis reporting threshold)
which were not included in the general ledger.
3. During our testing, differences in bank account numbers were noted in several instances between
either bank confirmations / bank statements / bank reconciliations compared to the bank account
listing which reflected the old account numbers. This was the case for accounts at five banks across
different Country Offices (‘CO’).
4. During our testing, differences in bank account numbers were noted from three bank
reconciliations (GL180090, GL180080, and GL168060) compared to the bank account listing as a
result of typos made on the bank reconciliations. The account numbers per Plan Inc. bank account
listing for these accounts, however, was correct.
5. During our testing, it was noted that two bank reconciliations (GL168010 and GL168110) had
incorrect local currencies input into the bank reconciliation in the currency field. This had no financial
impact on the bank reconciliations performed.
6. For two GL accounts (GL168120 and GL168129) differences amounting to €693,984 between the
denominated balance in bank reconciliation and the denominated balance per trial balance were
noted. Plan confirmed the amount pertains to the revaluation of currency and that the account should
not be reevaluated in local currency. This is a system error due to the wrong set up of the monthly
revaluation process for these two specific GL accounts.
Cause:
For the first point, Plan had acted on the request to close the bank account when the request had been
acknowledged but before it had been confirmed, and therefore removed the account from the cash
listing despite a formal confirmation letter from the bank not being received.
For the second, the root cause of this issue is the CO not following the process in relation to opening
bank accounts and appropriately informing Regional Hub (‘RH’) and Global Hub (‘GH’).
For points three and four, the revised bank account numbers were not updated on the bank account
listing which still contained the old account numbers; and for point five the CO had not picked up the
incorrect currency field noted or incorrect bank account number following review of the
reconciliation.
For the sixth point, two GL accounts had an incorrect variant set up causing differences between the
bank reconciliation and the trial balance.
Effect:
Classifying balances as closed creates risks over the completeness of the bank account listing. There is
a risk that a large number of accounts are classified as closed despite still being open or an account
with a material cash balance could be excluded from the cash listing.
Not identifying and reporting bank accounts on a timely basis to GH and bank account numbers
inaccurately reflected on the bank account listing or bank reconciliations creates risks over the
completeness of the bank account listing.
Per the Bank Secrecy Act, Plan is required through FBAR ( Foreign Bank and Financial Accounts, US
Federal Government) to report all non-US bank accounts to the US in March each year. FBAR then
performs ad hoc checks of various entities and if Plan is found not reporting a full list of active
accounts, they will receive penalty fines for not complying with US requirements.
Incorrect currencies or account numbers reflected on the bank reconciliations and bank fees not
included creates risk over the completeness and accuracy of bank reconciliations.
Additionally, the incorrect application of the variants creates the risk of inaccuracies performed on the
foreign currency translation of bank accounts.
Recommendation:
We recommend the following:
Bank accounts are not classified as closed until a formal closure letter from the bank is received.
The RHs perform timely monthly reviews to ensure the completeness of bank accounts and COs are
reminded of the process around opening and closing bank accounts and the required notifications to
RH and GH.
Management put in place a process whereby appropriate review of bank details is performed at a CO
level during the year end FBAR process as reliance is placed by GH on what is reported by the Country
Offices.
Management update the bank account listing to reflect updated bank account numbers.
Management ensure COs review the bank reconciliations for accuracy of financial and non-financial
data (such as account numbers).
Management ensure the correct set up of the monthly revaluation process for bank related GL
accounts.
Views of Responsible Officials and Management’s Corrective Action Plan :
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-004: Foreign exchange translation methodology (repeat of prior year finding 2022-004, 2021-005, 2020-006, 2019-006) (significant deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23, FY22, FY21, FY20 and FY19
Pass-through: All applicable
Criteria:
Accurate and reliable financial records of many kinds are necessary to meet ongoing financial
reporting and operational needs and requirements. The rate of exchange used throughout any given
month is the spot rate from the second to last working day of the prior month. This is not therefore the
‘the rate of exchange ruling at the date of the transaction’ in accordance with the Plan Inc. accounting
policies as stated in the financial statements.
Condition:
For all transactions, the impact of exchange rates takes place in the following stages:
At a transaction level
1. Translation from document currency (i.e. currency of income/expense per invoice) to local
currency at the time of initial recognition
2. Local currency to functional currency (Euro)
3. Translation to actual rate at date of settlement
4. Translation of outstanding amounts within the balance sheet at the period end rate
At the consolidation level
5. Functional currency to reporting currency (USD)
We note the following:
The monthly rate used for consolidation purposes is also the spot rate from the second to last day of
the previous month and not an appropriate average rate as required and we have noted an immaterial
misstatement relating to the translation of I&E into the reporting currency (USD).
As the foreign exchange methodology is unchanged from the prior year, the matter therefore still
remains open in FY23.
In FY23 management performed a retrospective analysis to assess the misstatement caused by using
the incorrect foreign exchange rate. We have assessed this analysis and confirmed the completeness,
inputs and mathematical accuracy thereof. We have confirmed there is an immaterial misstatement
arising as a result of the effect of using the incorrect foreign exchange rates for income and
expenditure.
Cause:
The rates used, as noted above, are a spot rate from the second to last day of the prior month, not a
transaction date rate or suitable weighted average, or another alternative. The current system does not
allow for the correct rate to be used.
Effect:
Foreign exchange translation methodology is currently not in accordance with accounting standards.
There are differences within the Plan Inc. financial statements that have been identified but not
corrected as a result of the foreign exchange translation methodology issues noted.
Recommendation:
As management plan, design and configure the new ERP system consideration should be given to the
need to input foreign exchange rates into the system on a daily basis to ensure compliance with the
accounting standards and Plan’s accounting policies.
Views of Responsible Officials and Management’s Corrective Action Plan:
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-003: Classification, completeness and accuracy of bank accounts (significant
deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23
Pass-through: All applicable
Criteria:
Accurate and reliable financial records, including listing of bank accounts and bank reconciliations,
are necessary to ensure that testing populations are complete, accurate and bank accounts are
correctly classified.
Condition:
Plan Inc. holds over 550 bank accounts between Global Hub, Plan Ltd and the Country Offices. The
following points were noted during the Plan Inc. financial statement audit:
1. From our testing performed over opening and closing bank accounts at the regional hub level, we
noted an account which was classified as closed prior to receiving a formal letter from the bank
confirming the closure. The account remains open with a balance of €36.
2. In the bank confirmation we independently received from ECO Bank Cameroon we noted two
additional bank account balances of €212k (immaterial and below de minimis reporting threshold)
which were not included in the general ledger.
3. During our testing, differences in bank account numbers were noted in several instances between
either bank confirmations / bank statements / bank reconciliations compared to the bank account
listing which reflected the old account numbers. This was the case for accounts at five banks across
different Country Offices (‘CO’).
4. During our testing, differences in bank account numbers were noted from three bank
reconciliations (GL180090, GL180080, and GL168060) compared to the bank account listing as a
result of typos made on the bank reconciliations. The account numbers per Plan Inc. bank account
listing for these accounts, however, was correct.
5. During our testing, it was noted that two bank reconciliations (GL168010 and GL168110) had
incorrect local currencies input into the bank reconciliation in the currency field. This had no financial
impact on the bank reconciliations performed.
6. For two GL accounts (GL168120 and GL168129) differences amounting to €693,984 between the
denominated balance in bank reconciliation and the denominated balance per trial balance were
noted. Plan confirmed the amount pertains to the revaluation of currency and that the account should
not be reevaluated in local currency. This is a system error due to the wrong set up of the monthly
revaluation process for these two specific GL accounts.
Cause:
For the first point, Plan had acted on the request to close the bank account when the request had been
acknowledged but before it had been confirmed, and therefore removed the account from the cash
listing despite a formal confirmation letter from the bank not being received.
For the second, the root cause of this issue is the CO not following the process in relation to opening
bank accounts and appropriately informing Regional Hub (‘RH’) and Global Hub (‘GH’).
For points three and four, the revised bank account numbers were not updated on the bank account
listing which still contained the old account numbers; and for point five the CO had not picked up the
incorrect currency field noted or incorrect bank account number following review of the
reconciliation.
For the sixth point, two GL accounts had an incorrect variant set up causing differences between the
bank reconciliation and the trial balance.
Effect:
Classifying balances as closed creates risks over the completeness of the bank account listing. There is
a risk that a large number of accounts are classified as closed despite still being open or an account
with a material cash balance could be excluded from the cash listing.
Not identifying and reporting bank accounts on a timely basis to GH and bank account numbers
inaccurately reflected on the bank account listing or bank reconciliations creates risks over the
completeness of the bank account listing.
Per the Bank Secrecy Act, Plan is required through FBAR ( Foreign Bank and Financial Accounts, US
Federal Government) to report all non-US bank accounts to the US in March each year. FBAR then
performs ad hoc checks of various entities and if Plan is found not reporting a full list of active
accounts, they will receive penalty fines for not complying with US requirements.
Incorrect currencies or account numbers reflected on the bank reconciliations and bank fees not
included creates risk over the completeness and accuracy of bank reconciliations.
Additionally, the incorrect application of the variants creates the risk of inaccuracies performed on the
foreign currency translation of bank accounts.
Recommendation:
We recommend the following:
Bank accounts are not classified as closed until a formal closure letter from the bank is received.
The RHs perform timely monthly reviews to ensure the completeness of bank accounts and COs are
reminded of the process around opening and closing bank accounts and the required notifications to
RH and GH.
Management put in place a process whereby appropriate review of bank details is performed at a CO
level during the year end FBAR process as reliance is placed by GH on what is reported by the Country
Offices.
Management update the bank account listing to reflect updated bank account numbers.
Management ensure COs review the bank reconciliations for accuracy of financial and non-financial
data (such as account numbers).
Management ensure the correct set up of the monthly revaluation process for bank related GL
accounts.
Views of Responsible Officials and Management’s Corrective Action Plan :
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-004: Foreign exchange translation methodology (repeat of prior year finding 2022-004, 2021-005, 2020-006, 2019-006) (significant deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23, FY22, FY21, FY20 and FY19
Pass-through: All applicable
Criteria:
Accurate and reliable financial records of many kinds are necessary to meet ongoing financial
reporting and operational needs and requirements. The rate of exchange used throughout any given
month is the spot rate from the second to last working day of the prior month. This is not therefore the
‘the rate of exchange ruling at the date of the transaction’ in accordance with the Plan Inc. accounting
policies as stated in the financial statements.
Condition:
For all transactions, the impact of exchange rates takes place in the following stages:
At a transaction level
1. Translation from document currency (i.e. currency of income/expense per invoice) to local
currency at the time of initial recognition
2. Local currency to functional currency (Euro)
3. Translation to actual rate at date of settlement
4. Translation of outstanding amounts within the balance sheet at the period end rate
At the consolidation level
5. Functional currency to reporting currency (USD)
We note the following:
The monthly rate used for consolidation purposes is also the spot rate from the second to last day of
the previous month and not an appropriate average rate as required and we have noted an immaterial
misstatement relating to the translation of I&E into the reporting currency (USD).
As the foreign exchange methodology is unchanged from the prior year, the matter therefore still
remains open in FY23.
In FY23 management performed a retrospective analysis to assess the misstatement caused by using
the incorrect foreign exchange rate. We have assessed this analysis and confirmed the completeness,
inputs and mathematical accuracy thereof. We have confirmed there is an immaterial misstatement
arising as a result of the effect of using the incorrect foreign exchange rates for income and
expenditure.
Cause:
The rates used, as noted above, are a spot rate from the second to last day of the prior month, not a
transaction date rate or suitable weighted average, or another alternative. The current system does not
allow for the correct rate to be used.
Effect:
Foreign exchange translation methodology is currently not in accordance with accounting standards.
There are differences within the Plan Inc. financial statements that have been identified but not
corrected as a result of the foreign exchange translation methodology issues noted.
Recommendation:
As management plan, design and configure the new ERP system consideration should be given to the
need to input foreign exchange rates into the system on a daily basis to ensure compliance with the
accounting standards and Plan’s accounting policies.
Views of Responsible Officials and Management’s Corrective Action Plan:
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-003: Classification, completeness and accuracy of bank accounts (significant
deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23
Pass-through: All applicable
Criteria:
Accurate and reliable financial records, including listing of bank accounts and bank reconciliations,
are necessary to ensure that testing populations are complete, accurate and bank accounts are
correctly classified.
Condition:
Plan Inc. holds over 550 bank accounts between Global Hub, Plan Ltd and the Country Offices. The
following points were noted during the Plan Inc. financial statement audit:
1. From our testing performed over opening and closing bank accounts at the regional hub level, we
noted an account which was classified as closed prior to receiving a formal letter from the bank
confirming the closure. The account remains open with a balance of €36.
2. In the bank confirmation we independently received from ECO Bank Cameroon we noted two
additional bank account balances of €212k (immaterial and below de minimis reporting threshold)
which were not included in the general ledger.
3. During our testing, differences in bank account numbers were noted in several instances between
either bank confirmations / bank statements / bank reconciliations compared to the bank account
listing which reflected the old account numbers. This was the case for accounts at five banks across
different Country Offices (‘CO’).
4. During our testing, differences in bank account numbers were noted from three bank
reconciliations (GL180090, GL180080, and GL168060) compared to the bank account listing as a
result of typos made on the bank reconciliations. The account numbers per Plan Inc. bank account
listing for these accounts, however, was correct.
5. During our testing, it was noted that two bank reconciliations (GL168010 and GL168110) had
incorrect local currencies input into the bank reconciliation in the currency field. This had no financial
impact on the bank reconciliations performed.
6. For two GL accounts (GL168120 and GL168129) differences amounting to €693,984 between the
denominated balance in bank reconciliation and the denominated balance per trial balance were
noted. Plan confirmed the amount pertains to the revaluation of currency and that the account should
not be reevaluated in local currency. This is a system error due to the wrong set up of the monthly
revaluation process for these two specific GL accounts.
Cause:
For the first point, Plan had acted on the request to close the bank account when the request had been
acknowledged but before it had been confirmed, and therefore removed the account from the cash
listing despite a formal confirmation letter from the bank not being received.
For the second, the root cause of this issue is the CO not following the process in relation to opening
bank accounts and appropriately informing Regional Hub (‘RH’) and Global Hub (‘GH’).
For points three and four, the revised bank account numbers were not updated on the bank account
listing which still contained the old account numbers; and for point five the CO had not picked up the
incorrect currency field noted or incorrect bank account number following review of the
reconciliation.
For the sixth point, two GL accounts had an incorrect variant set up causing differences between the
bank reconciliation and the trial balance.
Effect:
Classifying balances as closed creates risks over the completeness of the bank account listing. There is
a risk that a large number of accounts are classified as closed despite still being open or an account
with a material cash balance could be excluded from the cash listing.
Not identifying and reporting bank accounts on a timely basis to GH and bank account numbers
inaccurately reflected on the bank account listing or bank reconciliations creates risks over the
completeness of the bank account listing.
Per the Bank Secrecy Act, Plan is required through FBAR ( Foreign Bank and Financial Accounts, US
Federal Government) to report all non-US bank accounts to the US in March each year. FBAR then
performs ad hoc checks of various entities and if Plan is found not reporting a full list of active
accounts, they will receive penalty fines for not complying with US requirements.
Incorrect currencies or account numbers reflected on the bank reconciliations and bank fees not
included creates risk over the completeness and accuracy of bank reconciliations.
Additionally, the incorrect application of the variants creates the risk of inaccuracies performed on the
foreign currency translation of bank accounts.
Recommendation:
We recommend the following:
Bank accounts are not classified as closed until a formal closure letter from the bank is received.
The RHs perform timely monthly reviews to ensure the completeness of bank accounts and COs are
reminded of the process around opening and closing bank accounts and the required notifications to
RH and GH.
Management put in place a process whereby appropriate review of bank details is performed at a CO
level during the year end FBAR process as reliance is placed by GH on what is reported by the Country
Offices.
Management update the bank account listing to reflect updated bank account numbers.
Management ensure COs review the bank reconciliations for accuracy of financial and non-financial
data (such as account numbers).
Management ensure the correct set up of the monthly revaluation process for bank related GL
accounts.
Views of Responsible Officials and Management’s Corrective Action Plan :
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-004: Foreign exchange translation methodology (repeat of prior year finding 2022-004, 2021-005, 2020-006, 2019-006) (significant deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23, FY22, FY21, FY20 and FY19
Pass-through: All applicable
Criteria:
Accurate and reliable financial records of many kinds are necessary to meet ongoing financial
reporting and operational needs and requirements. The rate of exchange used throughout any given
month is the spot rate from the second to last working day of the prior month. This is not therefore the
‘the rate of exchange ruling at the date of the transaction’ in accordance with the Plan Inc. accounting
policies as stated in the financial statements.
Condition:
For all transactions, the impact of exchange rates takes place in the following stages:
At a transaction level
1. Translation from document currency (i.e. currency of income/expense per invoice) to local
currency at the time of initial recognition
2. Local currency to functional currency (Euro)
3. Translation to actual rate at date of settlement
4. Translation of outstanding amounts within the balance sheet at the period end rate
At the consolidation level
5. Functional currency to reporting currency (USD)
We note the following:
The monthly rate used for consolidation purposes is also the spot rate from the second to last day of
the previous month and not an appropriate average rate as required and we have noted an immaterial
misstatement relating to the translation of I&E into the reporting currency (USD).
As the foreign exchange methodology is unchanged from the prior year, the matter therefore still
remains open in FY23.
In FY23 management performed a retrospective analysis to assess the misstatement caused by using
the incorrect foreign exchange rate. We have assessed this analysis and confirmed the completeness,
inputs and mathematical accuracy thereof. We have confirmed there is an immaterial misstatement
arising as a result of the effect of using the incorrect foreign exchange rates for income and
expenditure.
Cause:
The rates used, as noted above, are a spot rate from the second to last day of the prior month, not a
transaction date rate or suitable weighted average, or another alternative. The current system does not
allow for the correct rate to be used.
Effect:
Foreign exchange translation methodology is currently not in accordance with accounting standards.
There are differences within the Plan Inc. financial statements that have been identified but not
corrected as a result of the foreign exchange translation methodology issues noted.
Recommendation:
As management plan, design and configure the new ERP system consideration should be given to the
need to input foreign exchange rates into the system on a daily basis to ensure compliance with the
accounting standards and Plan’s accounting policies.
Views of Responsible Officials and Management’s Corrective Action Plan:
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-003: Classification, completeness and accuracy of bank accounts (significant
deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23
Pass-through: All applicable
Criteria:
Accurate and reliable financial records, including listing of bank accounts and bank reconciliations,
are necessary to ensure that testing populations are complete, accurate and bank accounts are
correctly classified.
Condition:
Plan Inc. holds over 550 bank accounts between Global Hub, Plan Ltd and the Country Offices. The
following points were noted during the Plan Inc. financial statement audit:
1. From our testing performed over opening and closing bank accounts at the regional hub level, we
noted an account which was classified as closed prior to receiving a formal letter from the bank
confirming the closure. The account remains open with a balance of €36.
2. In the bank confirmation we independently received from ECO Bank Cameroon we noted two
additional bank account balances of €212k (immaterial and below de minimis reporting threshold)
which were not included in the general ledger.
3. During our testing, differences in bank account numbers were noted in several instances between
either bank confirmations / bank statements / bank reconciliations compared to the bank account
listing which reflected the old account numbers. This was the case for accounts at five banks across
different Country Offices (‘CO’).
4. During our testing, differences in bank account numbers were noted from three bank
reconciliations (GL180090, GL180080, and GL168060) compared to the bank account listing as a
result of typos made on the bank reconciliations. The account numbers per Plan Inc. bank account
listing for these accounts, however, was correct.
5. During our testing, it was noted that two bank reconciliations (GL168010 and GL168110) had
incorrect local currencies input into the bank reconciliation in the currency field. This had no financial
impact on the bank reconciliations performed.
6. For two GL accounts (GL168120 and GL168129) differences amounting to €693,984 between the
denominated balance in bank reconciliation and the denominated balance per trial balance were
noted. Plan confirmed the amount pertains to the revaluation of currency and that the account should
not be reevaluated in local currency. This is a system error due to the wrong set up of the monthly
revaluation process for these two specific GL accounts.
Cause:
For the first point, Plan had acted on the request to close the bank account when the request had been
acknowledged but before it had been confirmed, and therefore removed the account from the cash
listing despite a formal confirmation letter from the bank not being received.
For the second, the root cause of this issue is the CO not following the process in relation to opening
bank accounts and appropriately informing Regional Hub (‘RH’) and Global Hub (‘GH’).
For points three and four, the revised bank account numbers were not updated on the bank account
listing which still contained the old account numbers; and for point five the CO had not picked up the
incorrect currency field noted or incorrect bank account number following review of the
reconciliation.
For the sixth point, two GL accounts had an incorrect variant set up causing differences between the
bank reconciliation and the trial balance.
Effect:
Classifying balances as closed creates risks over the completeness of the bank account listing. There is
a risk that a large number of accounts are classified as closed despite still being open or an account
with a material cash balance could be excluded from the cash listing.
Not identifying and reporting bank accounts on a timely basis to GH and bank account numbers
inaccurately reflected on the bank account listing or bank reconciliations creates risks over the
completeness of the bank account listing.
Per the Bank Secrecy Act, Plan is required through FBAR ( Foreign Bank and Financial Accounts, US
Federal Government) to report all non-US bank accounts to the US in March each year. FBAR then
performs ad hoc checks of various entities and if Plan is found not reporting a full list of active
accounts, they will receive penalty fines for not complying with US requirements.
Incorrect currencies or account numbers reflected on the bank reconciliations and bank fees not
included creates risk over the completeness and accuracy of bank reconciliations.
Additionally, the incorrect application of the variants creates the risk of inaccuracies performed on the
foreign currency translation of bank accounts.
Recommendation:
We recommend the following:
Bank accounts are not classified as closed until a formal closure letter from the bank is received.
The RHs perform timely monthly reviews to ensure the completeness of bank accounts and COs are
reminded of the process around opening and closing bank accounts and the required notifications to
RH and GH.
Management put in place a process whereby appropriate review of bank details is performed at a CO
level during the year end FBAR process as reliance is placed by GH on what is reported by the Country
Offices.
Management update the bank account listing to reflect updated bank account numbers.
Management ensure COs review the bank reconciliations for accuracy of financial and non-financial
data (such as account numbers).
Management ensure the correct set up of the monthly revaluation process for bank related GL
accounts.
Views of Responsible Officials and Management’s Corrective Action Plan :
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-004: Foreign exchange translation methodology (repeat of prior year finding 2022-004, 2021-005, 2020-006, 2019-006) (significant deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23, FY22, FY21, FY20 and FY19
Pass-through: All applicable
Criteria:
Accurate and reliable financial records of many kinds are necessary to meet ongoing financial
reporting and operational needs and requirements. The rate of exchange used throughout any given
month is the spot rate from the second to last working day of the prior month. This is not therefore the
‘the rate of exchange ruling at the date of the transaction’ in accordance with the Plan Inc. accounting
policies as stated in the financial statements.
Condition:
For all transactions, the impact of exchange rates takes place in the following stages:
At a transaction level
1. Translation from document currency (i.e. currency of income/expense per invoice) to local
currency at the time of initial recognition
2. Local currency to functional currency (Euro)
3. Translation to actual rate at date of settlement
4. Translation of outstanding amounts within the balance sheet at the period end rate
At the consolidation level
5. Functional currency to reporting currency (USD)
We note the following:
The monthly rate used for consolidation purposes is also the spot rate from the second to last day of
the previous month and not an appropriate average rate as required and we have noted an immaterial
misstatement relating to the translation of I&E into the reporting currency (USD).
As the foreign exchange methodology is unchanged from the prior year, the matter therefore still
remains open in FY23.
In FY23 management performed a retrospective analysis to assess the misstatement caused by using
the incorrect foreign exchange rate. We have assessed this analysis and confirmed the completeness,
inputs and mathematical accuracy thereof. We have confirmed there is an immaterial misstatement
arising as a result of the effect of using the incorrect foreign exchange rates for income and
expenditure.
Cause:
The rates used, as noted above, are a spot rate from the second to last day of the prior month, not a
transaction date rate or suitable weighted average, or another alternative. The current system does not
allow for the correct rate to be used.
Effect:
Foreign exchange translation methodology is currently not in accordance with accounting standards.
There are differences within the Plan Inc. financial statements that have been identified but not
corrected as a result of the foreign exchange translation methodology issues noted.
Recommendation:
As management plan, design and configure the new ERP system consideration should be given to the
need to input foreign exchange rates into the system on a daily basis to ensure compliance with the
accounting standards and Plan’s accounting policies.
Views of Responsible Officials and Management’s Corrective Action Plan:
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-003: Classification, completeness and accuracy of bank accounts (significant
deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23
Pass-through: All applicable
Criteria:
Accurate and reliable financial records, including listing of bank accounts and bank reconciliations,
are necessary to ensure that testing populations are complete, accurate and bank accounts are
correctly classified.
Condition:
Plan Inc. holds over 550 bank accounts between Global Hub, Plan Ltd and the Country Offices. The
following points were noted during the Plan Inc. financial statement audit:
1. From our testing performed over opening and closing bank accounts at the regional hub level, we
noted an account which was classified as closed prior to receiving a formal letter from the bank
confirming the closure. The account remains open with a balance of €36.
2. In the bank confirmation we independently received from ECO Bank Cameroon we noted two
additional bank account balances of €212k (immaterial and below de minimis reporting threshold)
which were not included in the general ledger.
3. During our testing, differences in bank account numbers were noted in several instances between
either bank confirmations / bank statements / bank reconciliations compared to the bank account
listing which reflected the old account numbers. This was the case for accounts at five banks across
different Country Offices (‘CO’).
4. During our testing, differences in bank account numbers were noted from three bank
reconciliations (GL180090, GL180080, and GL168060) compared to the bank account listing as a
result of typos made on the bank reconciliations. The account numbers per Plan Inc. bank account
listing for these accounts, however, was correct.
5. During our testing, it was noted that two bank reconciliations (GL168010 and GL168110) had
incorrect local currencies input into the bank reconciliation in the currency field. This had no financial
impact on the bank reconciliations performed.
6. For two GL accounts (GL168120 and GL168129) differences amounting to €693,984 between the
denominated balance in bank reconciliation and the denominated balance per trial balance were
noted. Plan confirmed the amount pertains to the revaluation of currency and that the account should
not be reevaluated in local currency. This is a system error due to the wrong set up of the monthly
revaluation process for these two specific GL accounts.
Cause:
For the first point, Plan had acted on the request to close the bank account when the request had been
acknowledged but before it had been confirmed, and therefore removed the account from the cash
listing despite a formal confirmation letter from the bank not being received.
For the second, the root cause of this issue is the CO not following the process in relation to opening
bank accounts and appropriately informing Regional Hub (‘RH’) and Global Hub (‘GH’).
For points three and four, the revised bank account numbers were not updated on the bank account
listing which still contained the old account numbers; and for point five the CO had not picked up the
incorrect currency field noted or incorrect bank account number following review of the
reconciliation.
For the sixth point, two GL accounts had an incorrect variant set up causing differences between the
bank reconciliation and the trial balance.
Effect:
Classifying balances as closed creates risks over the completeness of the bank account listing. There is
a risk that a large number of accounts are classified as closed despite still being open or an account
with a material cash balance could be excluded from the cash listing.
Not identifying and reporting bank accounts on a timely basis to GH and bank account numbers
inaccurately reflected on the bank account listing or bank reconciliations creates risks over the
completeness of the bank account listing.
Per the Bank Secrecy Act, Plan is required through FBAR ( Foreign Bank and Financial Accounts, US
Federal Government) to report all non-US bank accounts to the US in March each year. FBAR then
performs ad hoc checks of various entities and if Plan is found not reporting a full list of active
accounts, they will receive penalty fines for not complying with US requirements.
Incorrect currencies or account numbers reflected on the bank reconciliations and bank fees not
included creates risk over the completeness and accuracy of bank reconciliations.
Additionally, the incorrect application of the variants creates the risk of inaccuracies performed on the
foreign currency translation of bank accounts.
Recommendation:
We recommend the following:
Bank accounts are not classified as closed until a formal closure letter from the bank is received.
The RHs perform timely monthly reviews to ensure the completeness of bank accounts and COs are
reminded of the process around opening and closing bank accounts and the required notifications to
RH and GH.
Management put in place a process whereby appropriate review of bank details is performed at a CO
level during the year end FBAR process as reliance is placed by GH on what is reported by the Country
Offices.
Management update the bank account listing to reflect updated bank account numbers.
Management ensure COs review the bank reconciliations for accuracy of financial and non-financial
data (such as account numbers).
Management ensure the correct set up of the monthly revaluation process for bank related GL
accounts.
Views of Responsible Officials and Management’s Corrective Action Plan :
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-004: Foreign exchange translation methodology (repeat of prior year finding 2022-004, 2021-005, 2020-006, 2019-006) (significant deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23, FY22, FY21, FY20 and FY19
Pass-through: All applicable
Criteria:
Accurate and reliable financial records of many kinds are necessary to meet ongoing financial
reporting and operational needs and requirements. The rate of exchange used throughout any given
month is the spot rate from the second to last working day of the prior month. This is not therefore the
‘the rate of exchange ruling at the date of the transaction’ in accordance with the Plan Inc. accounting
policies as stated in the financial statements.
Condition:
For all transactions, the impact of exchange rates takes place in the following stages:
At a transaction level
1. Translation from document currency (i.e. currency of income/expense per invoice) to local
currency at the time of initial recognition
2. Local currency to functional currency (Euro)
3. Translation to actual rate at date of settlement
4. Translation of outstanding amounts within the balance sheet at the period end rate
At the consolidation level
5. Functional currency to reporting currency (USD)
We note the following:
The monthly rate used for consolidation purposes is also the spot rate from the second to last day of
the previous month and not an appropriate average rate as required and we have noted an immaterial
misstatement relating to the translation of I&E into the reporting currency (USD).
As the foreign exchange methodology is unchanged from the prior year, the matter therefore still
remains open in FY23.
In FY23 management performed a retrospective analysis to assess the misstatement caused by using
the incorrect foreign exchange rate. We have assessed this analysis and confirmed the completeness,
inputs and mathematical accuracy thereof. We have confirmed there is an immaterial misstatement
arising as a result of the effect of using the incorrect foreign exchange rates for income and
expenditure.
Cause:
The rates used, as noted above, are a spot rate from the second to last day of the prior month, not a
transaction date rate or suitable weighted average, or another alternative. The current system does not
allow for the correct rate to be used.
Effect:
Foreign exchange translation methodology is currently not in accordance with accounting standards.
There are differences within the Plan Inc. financial statements that have been identified but not
corrected as a result of the foreign exchange translation methodology issues noted.
Recommendation:
As management plan, design and configure the new ERP system consideration should be given to the
need to input foreign exchange rates into the system on a daily basis to ensure compliance with the
accounting standards and Plan’s accounting policies.
Views of Responsible Officials and Management’s Corrective Action Plan:
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-003: Classification, completeness and accuracy of bank accounts (significant
deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23
Pass-through: All applicable
Criteria:
Accurate and reliable financial records, including listing of bank accounts and bank reconciliations,
are necessary to ensure that testing populations are complete, accurate and bank accounts are
correctly classified.
Condition:
Plan Inc. holds over 550 bank accounts between Global Hub, Plan Ltd and the Country Offices. The
following points were noted during the Plan Inc. financial statement audit:
1. From our testing performed over opening and closing bank accounts at the regional hub level, we
noted an account which was classified as closed prior to receiving a formal letter from the bank
confirming the closure. The account remains open with a balance of €36.
2. In the bank confirmation we independently received from ECO Bank Cameroon we noted two
additional bank account balances of €212k (immaterial and below de minimis reporting threshold)
which were not included in the general ledger.
3. During our testing, differences in bank account numbers were noted in several instances between
either bank confirmations / bank statements / bank reconciliations compared to the bank account
listing which reflected the old account numbers. This was the case for accounts at five banks across
different Country Offices (‘CO’).
4. During our testing, differences in bank account numbers were noted from three bank
reconciliations (GL180090, GL180080, and GL168060) compared to the bank account listing as a
result of typos made on the bank reconciliations. The account numbers per Plan Inc. bank account
listing for these accounts, however, was correct.
5. During our testing, it was noted that two bank reconciliations (GL168010 and GL168110) had
incorrect local currencies input into the bank reconciliation in the currency field. This had no financial
impact on the bank reconciliations performed.
6. For two GL accounts (GL168120 and GL168129) differences amounting to €693,984 between the
denominated balance in bank reconciliation and the denominated balance per trial balance were
noted. Plan confirmed the amount pertains to the revaluation of currency and that the account should
not be reevaluated in local currency. This is a system error due to the wrong set up of the monthly
revaluation process for these two specific GL accounts.
Cause:
For the first point, Plan had acted on the request to close the bank account when the request had been
acknowledged but before it had been confirmed, and therefore removed the account from the cash
listing despite a formal confirmation letter from the bank not being received.
For the second, the root cause of this issue is the CO not following the process in relation to opening
bank accounts and appropriately informing Regional Hub (‘RH’) and Global Hub (‘GH’).
For points three and four, the revised bank account numbers were not updated on the bank account
listing which still contained the old account numbers; and for point five the CO had not picked up the
incorrect currency field noted or incorrect bank account number following review of the
reconciliation.
For the sixth point, two GL accounts had an incorrect variant set up causing differences between the
bank reconciliation and the trial balance.
Effect:
Classifying balances as closed creates risks over the completeness of the bank account listing. There is
a risk that a large number of accounts are classified as closed despite still being open or an account
with a material cash balance could be excluded from the cash listing.
Not identifying and reporting bank accounts on a timely basis to GH and bank account numbers
inaccurately reflected on the bank account listing or bank reconciliations creates risks over the
completeness of the bank account listing.
Per the Bank Secrecy Act, Plan is required through FBAR ( Foreign Bank and Financial Accounts, US
Federal Government) to report all non-US bank accounts to the US in March each year. FBAR then
performs ad hoc checks of various entities and if Plan is found not reporting a full list of active
accounts, they will receive penalty fines for not complying with US requirements.
Incorrect currencies or account numbers reflected on the bank reconciliations and bank fees not
included creates risk over the completeness and accuracy of bank reconciliations.
Additionally, the incorrect application of the variants creates the risk of inaccuracies performed on the
foreign currency translation of bank accounts.
Recommendation:
We recommend the following:
Bank accounts are not classified as closed until a formal closure letter from the bank is received.
The RHs perform timely monthly reviews to ensure the completeness of bank accounts and COs are
reminded of the process around opening and closing bank accounts and the required notifications to
RH and GH.
Management put in place a process whereby appropriate review of bank details is performed at a CO
level during the year end FBAR process as reliance is placed by GH on what is reported by the Country
Offices.
Management update the bank account listing to reflect updated bank account numbers.
Management ensure COs review the bank reconciliations for accuracy of financial and non-financial
data (such as account numbers).
Management ensure the correct set up of the monthly revaluation process for bank related GL
accounts.
Views of Responsible Officials and Management’s Corrective Action Plan :
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-004: Foreign exchange translation methodology (repeat of prior year finding 2022-004, 2021-005, 2020-006, 2019-006) (significant deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23, FY22, FY21, FY20 and FY19
Pass-through: All applicable
Criteria:
Accurate and reliable financial records of many kinds are necessary to meet ongoing financial
reporting and operational needs and requirements. The rate of exchange used throughout any given
month is the spot rate from the second to last working day of the prior month. This is not therefore the
‘the rate of exchange ruling at the date of the transaction’ in accordance with the Plan Inc. accounting
policies as stated in the financial statements.
Condition:
For all transactions, the impact of exchange rates takes place in the following stages:
At a transaction level
1. Translation from document currency (i.e. currency of income/expense per invoice) to local
currency at the time of initial recognition
2. Local currency to functional currency (Euro)
3. Translation to actual rate at date of settlement
4. Translation of outstanding amounts within the balance sheet at the period end rate
At the consolidation level
5. Functional currency to reporting currency (USD)
We note the following:
The monthly rate used for consolidation purposes is also the spot rate from the second to last day of
the previous month and not an appropriate average rate as required and we have noted an immaterial
misstatement relating to the translation of I&E into the reporting currency (USD).
As the foreign exchange methodology is unchanged from the prior year, the matter therefore still
remains open in FY23.
In FY23 management performed a retrospective analysis to assess the misstatement caused by using
the incorrect foreign exchange rate. We have assessed this analysis and confirmed the completeness,
inputs and mathematical accuracy thereof. We have confirmed there is an immaterial misstatement
arising as a result of the effect of using the incorrect foreign exchange rates for income and
expenditure.
Cause:
The rates used, as noted above, are a spot rate from the second to last day of the prior month, not a
transaction date rate or suitable weighted average, or another alternative. The current system does not
allow for the correct rate to be used.
Effect:
Foreign exchange translation methodology is currently not in accordance with accounting standards.
There are differences within the Plan Inc. financial statements that have been identified but not
corrected as a result of the foreign exchange translation methodology issues noted.
Recommendation:
As management plan, design and configure the new ERP system consideration should be given to the
need to input foreign exchange rates into the system on a daily basis to ensure compliance with the
accounting standards and Plan’s accounting policies.
Views of Responsible Officials and Management’s Corrective Action Plan:
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-003: Classification, completeness and accuracy of bank accounts (significant
deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23
Pass-through: All applicable
Criteria:
Accurate and reliable financial records, including listing of bank accounts and bank reconciliations,
are necessary to ensure that testing populations are complete, accurate and bank accounts are
correctly classified.
Condition:
Plan Inc. holds over 550 bank accounts between Global Hub, Plan Ltd and the Country Offices. The
following points were noted during the Plan Inc. financial statement audit:
1. From our testing performed over opening and closing bank accounts at the regional hub level, we
noted an account which was classified as closed prior to receiving a formal letter from the bank
confirming the closure. The account remains open with a balance of €36.
2. In the bank confirmation we independently received from ECO Bank Cameroon we noted two
additional bank account balances of €212k (immaterial and below de minimis reporting threshold)
which were not included in the general ledger.
3. During our testing, differences in bank account numbers were noted in several instances between
either bank confirmations / bank statements / bank reconciliations compared to the bank account
listing which reflected the old account numbers. This was the case for accounts at five banks across
different Country Offices (‘CO’).
4. During our testing, differences in bank account numbers were noted from three bank
reconciliations (GL180090, GL180080, and GL168060) compared to the bank account listing as a
result of typos made on the bank reconciliations. The account numbers per Plan Inc. bank account
listing for these accounts, however, was correct.
5. During our testing, it was noted that two bank reconciliations (GL168010 and GL168110) had
incorrect local currencies input into the bank reconciliation in the currency field. This had no financial
impact on the bank reconciliations performed.
6. For two GL accounts (GL168120 and GL168129) differences amounting to €693,984 between the
denominated balance in bank reconciliation and the denominated balance per trial balance were
noted. Plan confirmed the amount pertains to the revaluation of currency and that the account should
not be reevaluated in local currency. This is a system error due to the wrong set up of the monthly
revaluation process for these two specific GL accounts.
Cause:
For the first point, Plan had acted on the request to close the bank account when the request had been
acknowledged but before it had been confirmed, and therefore removed the account from the cash
listing despite a formal confirmation letter from the bank not being received.
For the second, the root cause of this issue is the CO not following the process in relation to opening
bank accounts and appropriately informing Regional Hub (‘RH’) and Global Hub (‘GH’).
For points three and four, the revised bank account numbers were not updated on the bank account
listing which still contained the old account numbers; and for point five the CO had not picked up the
incorrect currency field noted or incorrect bank account number following review of the
reconciliation.
For the sixth point, two GL accounts had an incorrect variant set up causing differences between the
bank reconciliation and the trial balance.
Effect:
Classifying balances as closed creates risks over the completeness of the bank account listing. There is
a risk that a large number of accounts are classified as closed despite still being open or an account
with a material cash balance could be excluded from the cash listing.
Not identifying and reporting bank accounts on a timely basis to GH and bank account numbers
inaccurately reflected on the bank account listing or bank reconciliations creates risks over the
completeness of the bank account listing.
Per the Bank Secrecy Act, Plan is required through FBAR ( Foreign Bank and Financial Accounts, US
Federal Government) to report all non-US bank accounts to the US in March each year. FBAR then
performs ad hoc checks of various entities and if Plan is found not reporting a full list of active
accounts, they will receive penalty fines for not complying with US requirements.
Incorrect currencies or account numbers reflected on the bank reconciliations and bank fees not
included creates risk over the completeness and accuracy of bank reconciliations.
Additionally, the incorrect application of the variants creates the risk of inaccuracies performed on the
foreign currency translation of bank accounts.
Recommendation:
We recommend the following:
Bank accounts are not classified as closed until a formal closure letter from the bank is received.
The RHs perform timely monthly reviews to ensure the completeness of bank accounts and COs are
reminded of the process around opening and closing bank accounts and the required notifications to
RH and GH.
Management put in place a process whereby appropriate review of bank details is performed at a CO
level during the year end FBAR process as reliance is placed by GH on what is reported by the Country
Offices.
Management update the bank account listing to reflect updated bank account numbers.
Management ensure COs review the bank reconciliations for accuracy of financial and non-financial
data (such as account numbers).
Management ensure the correct set up of the monthly revaluation process for bank related GL
accounts.
Views of Responsible Officials and Management’s Corrective Action Plan :
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-004: Foreign exchange translation methodology (repeat of prior year finding 2022-004, 2021-005, 2020-006, 2019-006) (significant deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23, FY22, FY21, FY20 and FY19
Pass-through: All applicable
Criteria:
Accurate and reliable financial records of many kinds are necessary to meet ongoing financial
reporting and operational needs and requirements. The rate of exchange used throughout any given
month is the spot rate from the second to last working day of the prior month. This is not therefore the
‘the rate of exchange ruling at the date of the transaction’ in accordance with the Plan Inc. accounting
policies as stated in the financial statements.
Condition:
For all transactions, the impact of exchange rates takes place in the following stages:
At a transaction level
1. Translation from document currency (i.e. currency of income/expense per invoice) to local
currency at the time of initial recognition
2. Local currency to functional currency (Euro)
3. Translation to actual rate at date of settlement
4. Translation of outstanding amounts within the balance sheet at the period end rate
At the consolidation level
5. Functional currency to reporting currency (USD)
We note the following:
The monthly rate used for consolidation purposes is also the spot rate from the second to last day of
the previous month and not an appropriate average rate as required and we have noted an immaterial
misstatement relating to the translation of I&E into the reporting currency (USD).
As the foreign exchange methodology is unchanged from the prior year, the matter therefore still
remains open in FY23.
In FY23 management performed a retrospective analysis to assess the misstatement caused by using
the incorrect foreign exchange rate. We have assessed this analysis and confirmed the completeness,
inputs and mathematical accuracy thereof. We have confirmed there is an immaterial misstatement
arising as a result of the effect of using the incorrect foreign exchange rates for income and
expenditure.
Cause:
The rates used, as noted above, are a spot rate from the second to last day of the prior month, not a
transaction date rate or suitable weighted average, or another alternative. The current system does not
allow for the correct rate to be used.
Effect:
Foreign exchange translation methodology is currently not in accordance with accounting standards.
There are differences within the Plan Inc. financial statements that have been identified but not
corrected as a result of the foreign exchange translation methodology issues noted.
Recommendation:
As management plan, design and configure the new ERP system consideration should be given to the
need to input foreign exchange rates into the system on a daily basis to ensure compliance with the
accounting standards and Plan’s accounting policies.
Views of Responsible Officials and Management’s Corrective Action Plan:
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-003: Classification, completeness and accuracy of bank accounts (significant
deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23
Pass-through: All applicable
Criteria:
Accurate and reliable financial records, including listing of bank accounts and bank reconciliations,
are necessary to ensure that testing populations are complete, accurate and bank accounts are
correctly classified.
Condition:
Plan Inc. holds over 550 bank accounts between Global Hub, Plan Ltd and the Country Offices. The
following points were noted during the Plan Inc. financial statement audit:
1. From our testing performed over opening and closing bank accounts at the regional hub level, we
noted an account which was classified as closed prior to receiving a formal letter from the bank
confirming the closure. The account remains open with a balance of €36.
2. In the bank confirmation we independently received from ECO Bank Cameroon we noted two
additional bank account balances of €212k (immaterial and below de minimis reporting threshold)
which were not included in the general ledger.
3. During our testing, differences in bank account numbers were noted in several instances between
either bank confirmations / bank statements / bank reconciliations compared to the bank account
listing which reflected the old account numbers. This was the case for accounts at five banks across
different Country Offices (‘CO’).
4. During our testing, differences in bank account numbers were noted from three bank
reconciliations (GL180090, GL180080, and GL168060) compared to the bank account listing as a
result of typos made on the bank reconciliations. The account numbers per Plan Inc. bank account
listing for these accounts, however, was correct.
5. During our testing, it was noted that two bank reconciliations (GL168010 and GL168110) had
incorrect local currencies input into the bank reconciliation in the currency field. This had no financial
impact on the bank reconciliations performed.
6. For two GL accounts (GL168120 and GL168129) differences amounting to €693,984 between the
denominated balance in bank reconciliation and the denominated balance per trial balance were
noted. Plan confirmed the amount pertains to the revaluation of currency and that the account should
not be reevaluated in local currency. This is a system error due to the wrong set up of the monthly
revaluation process for these two specific GL accounts.
Cause:
For the first point, Plan had acted on the request to close the bank account when the request had been
acknowledged but before it had been confirmed, and therefore removed the account from the cash
listing despite a formal confirmation letter from the bank not being received.
For the second, the root cause of this issue is the CO not following the process in relation to opening
bank accounts and appropriately informing Regional Hub (‘RH’) and Global Hub (‘GH’).
For points three and four, the revised bank account numbers were not updated on the bank account
listing which still contained the old account numbers; and for point five the CO had not picked up the
incorrect currency field noted or incorrect bank account number following review of the
reconciliation.
For the sixth point, two GL accounts had an incorrect variant set up causing differences between the
bank reconciliation and the trial balance.
Effect:
Classifying balances as closed creates risks over the completeness of the bank account listing. There is
a risk that a large number of accounts are classified as closed despite still being open or an account
with a material cash balance could be excluded from the cash listing.
Not identifying and reporting bank accounts on a timely basis to GH and bank account numbers
inaccurately reflected on the bank account listing or bank reconciliations creates risks over the
completeness of the bank account listing.
Per the Bank Secrecy Act, Plan is required through FBAR ( Foreign Bank and Financial Accounts, US
Federal Government) to report all non-US bank accounts to the US in March each year. FBAR then
performs ad hoc checks of various entities and if Plan is found not reporting a full list of active
accounts, they will receive penalty fines for not complying with US requirements.
Incorrect currencies or account numbers reflected on the bank reconciliations and bank fees not
included creates risk over the completeness and accuracy of bank reconciliations.
Additionally, the incorrect application of the variants creates the risk of inaccuracies performed on the
foreign currency translation of bank accounts.
Recommendation:
We recommend the following:
Bank accounts are not classified as closed until a formal closure letter from the bank is received.
The RHs perform timely monthly reviews to ensure the completeness of bank accounts and COs are
reminded of the process around opening and closing bank accounts and the required notifications to
RH and GH.
Management put in place a process whereby appropriate review of bank details is performed at a CO
level during the year end FBAR process as reliance is placed by GH on what is reported by the Country
Offices.
Management update the bank account listing to reflect updated bank account numbers.
Management ensure COs review the bank reconciliations for accuracy of financial and non-financial
data (such as account numbers).
Management ensure the correct set up of the monthly revaluation process for bank related GL
accounts.
Views of Responsible Officials and Management’s Corrective Action Plan :
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-004: Foreign exchange translation methodology (repeat of prior year finding 2022-004, 2021-005, 2020-006, 2019-006) (significant deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23, FY22, FY21, FY20 and FY19
Pass-through: All applicable
Criteria:
Accurate and reliable financial records of many kinds are necessary to meet ongoing financial
reporting and operational needs and requirements. The rate of exchange used throughout any given
month is the spot rate from the second to last working day of the prior month. This is not therefore the
‘the rate of exchange ruling at the date of the transaction’ in accordance with the Plan Inc. accounting
policies as stated in the financial statements.
Condition:
For all transactions, the impact of exchange rates takes place in the following stages:
At a transaction level
1. Translation from document currency (i.e. currency of income/expense per invoice) to local
currency at the time of initial recognition
2. Local currency to functional currency (Euro)
3. Translation to actual rate at date of settlement
4. Translation of outstanding amounts within the balance sheet at the period end rate
At the consolidation level
5. Functional currency to reporting currency (USD)
We note the following:
The monthly rate used for consolidation purposes is also the spot rate from the second to last day of
the previous month and not an appropriate average rate as required and we have noted an immaterial
misstatement relating to the translation of I&E into the reporting currency (USD).
As the foreign exchange methodology is unchanged from the prior year, the matter therefore still
remains open in FY23.
In FY23 management performed a retrospective analysis to assess the misstatement caused by using
the incorrect foreign exchange rate. We have assessed this analysis and confirmed the completeness,
inputs and mathematical accuracy thereof. We have confirmed there is an immaterial misstatement
arising as a result of the effect of using the incorrect foreign exchange rates for income and
expenditure.
Cause:
The rates used, as noted above, are a spot rate from the second to last day of the prior month, not a
transaction date rate or suitable weighted average, or another alternative. The current system does not
allow for the correct rate to be used.
Effect:
Foreign exchange translation methodology is currently not in accordance with accounting standards.
There are differences within the Plan Inc. financial statements that have been identified but not
corrected as a result of the foreign exchange translation methodology issues noted.
Recommendation:
As management plan, design and configure the new ERP system consideration should be given to the
need to input foreign exchange rates into the system on a daily basis to ensure compliance with the
accounting standards and Plan’s accounting policies.
Views of Responsible Officials and Management’s Corrective Action Plan:
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-003: Classification, completeness and accuracy of bank accounts (significant
deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23
Pass-through: All applicable
Criteria:
Accurate and reliable financial records, including listing of bank accounts and bank reconciliations,
are necessary to ensure that testing populations are complete, accurate and bank accounts are
correctly classified.
Condition:
Plan Inc. holds over 550 bank accounts between Global Hub, Plan Ltd and the Country Offices. The
following points were noted during the Plan Inc. financial statement audit:
1. From our testing performed over opening and closing bank accounts at the regional hub level, we
noted an account which was classified as closed prior to receiving a formal letter from the bank
confirming the closure. The account remains open with a balance of €36.
2. In the bank confirmation we independently received from ECO Bank Cameroon we noted two
additional bank account balances of €212k (immaterial and below de minimis reporting threshold)
which were not included in the general ledger.
3. During our testing, differences in bank account numbers were noted in several instances between
either bank confirmations / bank statements / bank reconciliations compared to the bank account
listing which reflected the old account numbers. This was the case for accounts at five banks across
different Country Offices (‘CO’).
4. During our testing, differences in bank account numbers were noted from three bank
reconciliations (GL180090, GL180080, and GL168060) compared to the bank account listing as a
result of typos made on the bank reconciliations. The account numbers per Plan Inc. bank account
listing for these accounts, however, was correct.
5. During our testing, it was noted that two bank reconciliations (GL168010 and GL168110) had
incorrect local currencies input into the bank reconciliation in the currency field. This had no financial
impact on the bank reconciliations performed.
6. For two GL accounts (GL168120 and GL168129) differences amounting to €693,984 between the
denominated balance in bank reconciliation and the denominated balance per trial balance were
noted. Plan confirmed the amount pertains to the revaluation of currency and that the account should
not be reevaluated in local currency. This is a system error due to the wrong set up of the monthly
revaluation process for these two specific GL accounts.
Cause:
For the first point, Plan had acted on the request to close the bank account when the request had been
acknowledged but before it had been confirmed, and therefore removed the account from the cash
listing despite a formal confirmation letter from the bank not being received.
For the second, the root cause of this issue is the CO not following the process in relation to opening
bank accounts and appropriately informing Regional Hub (‘RH’) and Global Hub (‘GH’).
For points three and four, the revised bank account numbers were not updated on the bank account
listing which still contained the old account numbers; and for point five the CO had not picked up the
incorrect currency field noted or incorrect bank account number following review of the
reconciliation.
For the sixth point, two GL accounts had an incorrect variant set up causing differences between the
bank reconciliation and the trial balance.
Effect:
Classifying balances as closed creates risks over the completeness of the bank account listing. There is
a risk that a large number of accounts are classified as closed despite still being open or an account
with a material cash balance could be excluded from the cash listing.
Not identifying and reporting bank accounts on a timely basis to GH and bank account numbers
inaccurately reflected on the bank account listing or bank reconciliations creates risks over the
completeness of the bank account listing.
Per the Bank Secrecy Act, Plan is required through FBAR ( Foreign Bank and Financial Accounts, US
Federal Government) to report all non-US bank accounts to the US in March each year. FBAR then
performs ad hoc checks of various entities and if Plan is found not reporting a full list of active
accounts, they will receive penalty fines for not complying with US requirements.
Incorrect currencies or account numbers reflected on the bank reconciliations and bank fees not
included creates risk over the completeness and accuracy of bank reconciliations.
Additionally, the incorrect application of the variants creates the risk of inaccuracies performed on the
foreign currency translation of bank accounts.
Recommendation:
We recommend the following:
Bank accounts are not classified as closed until a formal closure letter from the bank is received.
The RHs perform timely monthly reviews to ensure the completeness of bank accounts and COs are
reminded of the process around opening and closing bank accounts and the required notifications to
RH and GH.
Management put in place a process whereby appropriate review of bank details is performed at a CO
level during the year end FBAR process as reliance is placed by GH on what is reported by the Country
Offices.
Management update the bank account listing to reflect updated bank account numbers.
Management ensure COs review the bank reconciliations for accuracy of financial and non-financial
data (such as account numbers).
Management ensure the correct set up of the monthly revaluation process for bank related GL
accounts.
Views of Responsible Officials and Management’s Corrective Action Plan :
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-004: Foreign exchange translation methodology (repeat of prior year finding 2022-004, 2021-005, 2020-006, 2019-006) (significant deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23, FY22, FY21, FY20 and FY19
Pass-through: All applicable
Criteria:
Accurate and reliable financial records of many kinds are necessary to meet ongoing financial
reporting and operational needs and requirements. The rate of exchange used throughout any given
month is the spot rate from the second to last working day of the prior month. This is not therefore the
‘the rate of exchange ruling at the date of the transaction’ in accordance with the Plan Inc. accounting
policies as stated in the financial statements.
Condition:
For all transactions, the impact of exchange rates takes place in the following stages:
At a transaction level
1. Translation from document currency (i.e. currency of income/expense per invoice) to local
currency at the time of initial recognition
2. Local currency to functional currency (Euro)
3. Translation to actual rate at date of settlement
4. Translation of outstanding amounts within the balance sheet at the period end rate
At the consolidation level
5. Functional currency to reporting currency (USD)
We note the following:
The monthly rate used for consolidation purposes is also the spot rate from the second to last day of
the previous month and not an appropriate average rate as required and we have noted an immaterial
misstatement relating to the translation of I&E into the reporting currency (USD).
As the foreign exchange methodology is unchanged from the prior year, the matter therefore still
remains open in FY23.
In FY23 management performed a retrospective analysis to assess the misstatement caused by using
the incorrect foreign exchange rate. We have assessed this analysis and confirmed the completeness,
inputs and mathematical accuracy thereof. We have confirmed there is an immaterial misstatement
arising as a result of the effect of using the incorrect foreign exchange rates for income and
expenditure.
Cause:
The rates used, as noted above, are a spot rate from the second to last day of the prior month, not a
transaction date rate or suitable weighted average, or another alternative. The current system does not
allow for the correct rate to be used.
Effect:
Foreign exchange translation methodology is currently not in accordance with accounting standards.
There are differences within the Plan Inc. financial statements that have been identified but not
corrected as a result of the foreign exchange translation methodology issues noted.
Recommendation:
As management plan, design and configure the new ERP system consideration should be given to the
need to input foreign exchange rates into the system on a daily basis to ensure compliance with the
accounting standards and Plan’s accounting policies.
Views of Responsible Officials and Management’s Corrective Action Plan:
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-007: Suspension and debarment checks should be performed prior to doing
business with certain vendors
Federal Agency: U.S. Department of State for Ethiopia South Sudanese Refugee Assistance V and VI;
United States Agency for International Development (USAID)
Program: Ethiopia: South Sudanese Refugee Assistance V and VI; Ethiopia: BHA Tigray Child
Protection
Assistance Listing: 19.517 (Ethiopia); 98.001 (Ethiopia)
Award #: SPRMCO21CA3181 ETH102315 (Ethiopia), SPRMCO22CA0199 ETH102389 (Ethiopia);
720BHA21GR00199 ETH102324
Award year: FY23
Pass-through: Plan USA, Inc.
Criteria:
Non-federal entities are prohibited from contracting with or making subawards under covered
transactions to parties that are suspended or debarred. When a non-federal entity enters into a
covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as
defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or
otherwise excluded from participating in the transaction. This verification may be accomplished by (1)
checking the System for Award Management (SAM) Exclusions maintained by the General Services
Administration, (2) collecting a certification from the entity, or (3) adding a clause or condition to the
covered transaction with that entity (2 CFR section 180.300).
Condition :
Suspension and debarment checks are performed centrally by the compliance team based at Global
Hub (‘GH’). The compliance team obtains new vendor data from the finance system SAP on a weekly
basis and has a policy to check all vendors regardless of dollar value. Suspension and debarment
checks are performed over this list on a weekly basis using a third party ‘Automated Screening
Manager’ (‘ASM’) tool. In instances of one-off payments, the Country Office (‘CO’) sends a request via
email to the compliance team at GH to perform the suspension and debarment check. The results of
the ASM checks are shared with the COs.
We identified four samples out of a population of 67 samples where the date of the ASM check was
after the date of the transaction with the vendor. Management was therefore unable to evidence that a
suspension and debarment check had been performed prior to the transaction taking place. The time
period between the transaction dates of our samples and the date of the ASM checks ranged from one
day to 11 months.
The combined total of the four transactions was $19,108 and they occurred in one region (Ethiopia).
Cause:
The Global Hub compliance team was not notified on a timely basis of the new vendors by the
Ethiopia Country Office and therefore did not perform the suspension and debarment checks prior to
the transactions taking place.
Effect:
Vendors not checked if suspended or debarred prior to doing business with them could lead to
non-compliance to Uniform Guidance requirement.
Recommendation:
Management should ensure that COs are communicating with new vendors on a timely basis to ensure
that all vendors are checked for suspension and debarment before they are engaged and transacted
with and documentation is maintained demonstrating this check was completed.
Views of Responsible Officials and Management’s Corrective Action Plan:
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-003: Classification, completeness and accuracy of bank accounts (significant
deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23
Pass-through: All applicable
Criteria:
Accurate and reliable financial records, including listing of bank accounts and bank reconciliations,
are necessary to ensure that testing populations are complete, accurate and bank accounts are
correctly classified.
Condition:
Plan Inc. holds over 550 bank accounts between Global Hub, Plan Ltd and the Country Offices. The
following points were noted during the Plan Inc. financial statement audit:
1. From our testing performed over opening and closing bank accounts at the regional hub level, we
noted an account which was classified as closed prior to receiving a formal letter from the bank
confirming the closure. The account remains open with a balance of €36.
2. In the bank confirmation we independently received from ECO Bank Cameroon we noted two
additional bank account balances of €212k (immaterial and below de minimis reporting threshold)
which were not included in the general ledger.
3. During our testing, differences in bank account numbers were noted in several instances between
either bank confirmations / bank statements / bank reconciliations compared to the bank account
listing which reflected the old account numbers. This was the case for accounts at five banks across
different Country Offices (‘CO’).
4. During our testing, differences in bank account numbers were noted from three bank
reconciliations (GL180090, GL180080, and GL168060) compared to the bank account listing as a
result of typos made on the bank reconciliations. The account numbers per Plan Inc. bank account
listing for these accounts, however, was correct.
5. During our testing, it was noted that two bank reconciliations (GL168010 and GL168110) had
incorrect local currencies input into the bank reconciliation in the currency field. This had no financial
impact on the bank reconciliations performed.
6. For two GL accounts (GL168120 and GL168129) differences amounting to €693,984 between the
denominated balance in bank reconciliation and the denominated balance per trial balance were
noted. Plan confirmed the amount pertains to the revaluation of currency and that the account should
not be reevaluated in local currency. This is a system error due to the wrong set up of the monthly
revaluation process for these two specific GL accounts.
Cause:
For the first point, Plan had acted on the request to close the bank account when the request had been
acknowledged but before it had been confirmed, and therefore removed the account from the cash
listing despite a formal confirmation letter from the bank not being received.
For the second, the root cause of this issue is the CO not following the process in relation to opening
bank accounts and appropriately informing Regional Hub (‘RH’) and Global Hub (‘GH’).
For points three and four, the revised bank account numbers were not updated on the bank account
listing which still contained the old account numbers; and for point five the CO had not picked up the
incorrect currency field noted or incorrect bank account number following review of the
reconciliation.
For the sixth point, two GL accounts had an incorrect variant set up causing differences between the
bank reconciliation and the trial balance.
Effect:
Classifying balances as closed creates risks over the completeness of the bank account listing. There is
a risk that a large number of accounts are classified as closed despite still being open or an account
with a material cash balance could be excluded from the cash listing.
Not identifying and reporting bank accounts on a timely basis to GH and bank account numbers
inaccurately reflected on the bank account listing or bank reconciliations creates risks over the
completeness of the bank account listing.
Per the Bank Secrecy Act, Plan is required through FBAR ( Foreign Bank and Financial Accounts, US
Federal Government) to report all non-US bank accounts to the US in March each year. FBAR then
performs ad hoc checks of various entities and if Plan is found not reporting a full list of active
accounts, they will receive penalty fines for not complying with US requirements.
Incorrect currencies or account numbers reflected on the bank reconciliations and bank fees not
included creates risk over the completeness and accuracy of bank reconciliations.
Additionally, the incorrect application of the variants creates the risk of inaccuracies performed on the
foreign currency translation of bank accounts.
Recommendation:
We recommend the following:
Bank accounts are not classified as closed until a formal closure letter from the bank is received.
The RHs perform timely monthly reviews to ensure the completeness of bank accounts and COs are
reminded of the process around opening and closing bank accounts and the required notifications to
RH and GH.
Management put in place a process whereby appropriate review of bank details is performed at a CO
level during the year end FBAR process as reliance is placed by GH on what is reported by the Country
Offices.
Management update the bank account listing to reflect updated bank account numbers.
Management ensure COs review the bank reconciliations for accuracy of financial and non-financial
data (such as account numbers).
Management ensure the correct set up of the monthly revaluation process for bank related GL
accounts.
Views of Responsible Officials and Management’s Corrective Action Plan :
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-004: Foreign exchange translation methodology (repeat of prior year finding 2022-004, 2021-005, 2020-006, 2019-006) (significant deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23, FY22, FY21, FY20 and FY19
Pass-through: All applicable
Criteria:
Accurate and reliable financial records of many kinds are necessary to meet ongoing financial
reporting and operational needs and requirements. The rate of exchange used throughout any given
month is the spot rate from the second to last working day of the prior month. This is not therefore the
‘the rate of exchange ruling at the date of the transaction’ in accordance with the Plan Inc. accounting
policies as stated in the financial statements.
Condition:
For all transactions, the impact of exchange rates takes place in the following stages:
At a transaction level
1. Translation from document currency (i.e. currency of income/expense per invoice) to local
currency at the time of initial recognition
2. Local currency to functional currency (Euro)
3. Translation to actual rate at date of settlement
4. Translation of outstanding amounts within the balance sheet at the period end rate
At the consolidation level
5. Functional currency to reporting currency (USD)
We note the following:
The monthly rate used for consolidation purposes is also the spot rate from the second to last day of
the previous month and not an appropriate average rate as required and we have noted an immaterial
misstatement relating to the translation of I&E into the reporting currency (USD).
As the foreign exchange methodology is unchanged from the prior year, the matter therefore still
remains open in FY23.
In FY23 management performed a retrospective analysis to assess the misstatement caused by using
the incorrect foreign exchange rate. We have assessed this analysis and confirmed the completeness,
inputs and mathematical accuracy thereof. We have confirmed there is an immaterial misstatement
arising as a result of the effect of using the incorrect foreign exchange rates for income and
expenditure.
Cause:
The rates used, as noted above, are a spot rate from the second to last day of the prior month, not a
transaction date rate or suitable weighted average, or another alternative. The current system does not
allow for the correct rate to be used.
Effect:
Foreign exchange translation methodology is currently not in accordance with accounting standards.
There are differences within the Plan Inc. financial statements that have been identified but not
corrected as a result of the foreign exchange translation methodology issues noted.
Recommendation:
As management plan, design and configure the new ERP system consideration should be given to the
need to input foreign exchange rates into the system on a daily basis to ensure compliance with the
accounting standards and Plan’s accounting policies.
Views of Responsible Officials and Management’s Corrective Action Plan:
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-007: Suspension and debarment checks should be performed prior to doing
business with certain vendors
Federal Agency: U.S. Department of State for Ethiopia South Sudanese Refugee Assistance V and VI;
United States Agency for International Development (USAID)
Program: Ethiopia: South Sudanese Refugee Assistance V and VI; Ethiopia: BHA Tigray Child
Protection
Assistance Listing: 19.517 (Ethiopia); 98.001 (Ethiopia)
Award #: SPRMCO21CA3181 ETH102315 (Ethiopia), SPRMCO22CA0199 ETH102389 (Ethiopia);
720BHA21GR00199 ETH102324
Award year: FY23
Pass-through: Plan USA, Inc.
Criteria:
Non-federal entities are prohibited from contracting with or making subawards under covered
transactions to parties that are suspended or debarred. When a non-federal entity enters into a
covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as
defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or
otherwise excluded from participating in the transaction. This verification may be accomplished by (1)
checking the System for Award Management (SAM) Exclusions maintained by the General Services
Administration, (2) collecting a certification from the entity, or (3) adding a clause or condition to the
covered transaction with that entity (2 CFR section 180.300).
Condition :
Suspension and debarment checks are performed centrally by the compliance team based at Global
Hub (‘GH’). The compliance team obtains new vendor data from the finance system SAP on a weekly
basis and has a policy to check all vendors regardless of dollar value. Suspension and debarment
checks are performed over this list on a weekly basis using a third party ‘Automated Screening
Manager’ (‘ASM’) tool. In instances of one-off payments, the Country Office (‘CO’) sends a request via
email to the compliance team at GH to perform the suspension and debarment check. The results of
the ASM checks are shared with the COs.
We identified four samples out of a population of 67 samples where the date of the ASM check was
after the date of the transaction with the vendor. Management was therefore unable to evidence that a
suspension and debarment check had been performed prior to the transaction taking place. The time
period between the transaction dates of our samples and the date of the ASM checks ranged from one
day to 11 months.
The combined total of the four transactions was $19,108 and they occurred in one region (Ethiopia).
Cause:
The Global Hub compliance team was not notified on a timely basis of the new vendors by the
Ethiopia Country Office and therefore did not perform the suspension and debarment checks prior to
the transactions taking place.
Effect:
Vendors not checked if suspended or debarred prior to doing business with them could lead to
non-compliance to Uniform Guidance requirement.
Recommendation:
Management should ensure that COs are communicating with new vendors on a timely basis to ensure
that all vendors are checked for suspension and debarment before they are engaged and transacted
with and documentation is maintained demonstrating this check was completed.
Views of Responsible Officials and Management’s Corrective Action Plan:
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-003: Classification, completeness and accuracy of bank accounts (significant
deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23
Pass-through: All applicable
Criteria:
Accurate and reliable financial records, including listing of bank accounts and bank reconciliations,
are necessary to ensure that testing populations are complete, accurate and bank accounts are
correctly classified.
Condition:
Plan Inc. holds over 550 bank accounts between Global Hub, Plan Ltd and the Country Offices. The
following points were noted during the Plan Inc. financial statement audit:
1. From our testing performed over opening and closing bank accounts at the regional hub level, we
noted an account which was classified as closed prior to receiving a formal letter from the bank
confirming the closure. The account remains open with a balance of €36.
2. In the bank confirmation we independently received from ECO Bank Cameroon we noted two
additional bank account balances of €212k (immaterial and below de minimis reporting threshold)
which were not included in the general ledger.
3. During our testing, differences in bank account numbers were noted in several instances between
either bank confirmations / bank statements / bank reconciliations compared to the bank account
listing which reflected the old account numbers. This was the case for accounts at five banks across
different Country Offices (‘CO’).
4. During our testing, differences in bank account numbers were noted from three bank
reconciliations (GL180090, GL180080, and GL168060) compared to the bank account listing as a
result of typos made on the bank reconciliations. The account numbers per Plan Inc. bank account
listing for these accounts, however, was correct.
5. During our testing, it was noted that two bank reconciliations (GL168010 and GL168110) had
incorrect local currencies input into the bank reconciliation in the currency field. This had no financial
impact on the bank reconciliations performed.
6. For two GL accounts (GL168120 and GL168129) differences amounting to €693,984 between the
denominated balance in bank reconciliation and the denominated balance per trial balance were
noted. Plan confirmed the amount pertains to the revaluation of currency and that the account should
not be reevaluated in local currency. This is a system error due to the wrong set up of the monthly
revaluation process for these two specific GL accounts.
Cause:
For the first point, Plan had acted on the request to close the bank account when the request had been
acknowledged but before it had been confirmed, and therefore removed the account from the cash
listing despite a formal confirmation letter from the bank not being received.
For the second, the root cause of this issue is the CO not following the process in relation to opening
bank accounts and appropriately informing Regional Hub (‘RH’) and Global Hub (‘GH’).
For points three and four, the revised bank account numbers were not updated on the bank account
listing which still contained the old account numbers; and for point five the CO had not picked up the
incorrect currency field noted or incorrect bank account number following review of the
reconciliation.
For the sixth point, two GL accounts had an incorrect variant set up causing differences between the
bank reconciliation and the trial balance.
Effect:
Classifying balances as closed creates risks over the completeness of the bank account listing. There is
a risk that a large number of accounts are classified as closed despite still being open or an account
with a material cash balance could be excluded from the cash listing.
Not identifying and reporting bank accounts on a timely basis to GH and bank account numbers
inaccurately reflected on the bank account listing or bank reconciliations creates risks over the
completeness of the bank account listing.
Per the Bank Secrecy Act, Plan is required through FBAR ( Foreign Bank and Financial Accounts, US
Federal Government) to report all non-US bank accounts to the US in March each year. FBAR then
performs ad hoc checks of various entities and if Plan is found not reporting a full list of active
accounts, they will receive penalty fines for not complying with US requirements.
Incorrect currencies or account numbers reflected on the bank reconciliations and bank fees not
included creates risk over the completeness and accuracy of bank reconciliations.
Additionally, the incorrect application of the variants creates the risk of inaccuracies performed on the
foreign currency translation of bank accounts.
Recommendation:
We recommend the following:
Bank accounts are not classified as closed until a formal closure letter from the bank is received.
The RHs perform timely monthly reviews to ensure the completeness of bank accounts and COs are
reminded of the process around opening and closing bank accounts and the required notifications to
RH and GH.
Management put in place a process whereby appropriate review of bank details is performed at a CO
level during the year end FBAR process as reliance is placed by GH on what is reported by the Country
Offices.
Management update the bank account listing to reflect updated bank account numbers.
Management ensure COs review the bank reconciliations for accuracy of financial and non-financial
data (such as account numbers).
Management ensure the correct set up of the monthly revaluation process for bank related GL
accounts.
Views of Responsible Officials and Management’s Corrective Action Plan :
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-004: Foreign exchange translation methodology (repeat of prior year finding 2022-004, 2021-005, 2020-006, 2019-006) (significant deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23, FY22, FY21, FY20 and FY19
Pass-through: All applicable
Criteria:
Accurate and reliable financial records of many kinds are necessary to meet ongoing financial
reporting and operational needs and requirements. The rate of exchange used throughout any given
month is the spot rate from the second to last working day of the prior month. This is not therefore the
‘the rate of exchange ruling at the date of the transaction’ in accordance with the Plan Inc. accounting
policies as stated in the financial statements.
Condition:
For all transactions, the impact of exchange rates takes place in the following stages:
At a transaction level
1. Translation from document currency (i.e. currency of income/expense per invoice) to local
currency at the time of initial recognition
2. Local currency to functional currency (Euro)
3. Translation to actual rate at date of settlement
4. Translation of outstanding amounts within the balance sheet at the period end rate
At the consolidation level
5. Functional currency to reporting currency (USD)
We note the following:
The monthly rate used for consolidation purposes is also the spot rate from the second to last day of
the previous month and not an appropriate average rate as required and we have noted an immaterial
misstatement relating to the translation of I&E into the reporting currency (USD).
As the foreign exchange methodology is unchanged from the prior year, the matter therefore still
remains open in FY23.
In FY23 management performed a retrospective analysis to assess the misstatement caused by using
the incorrect foreign exchange rate. We have assessed this analysis and confirmed the completeness,
inputs and mathematical accuracy thereof. We have confirmed there is an immaterial misstatement
arising as a result of the effect of using the incorrect foreign exchange rates for income and
expenditure.
Cause:
The rates used, as noted above, are a spot rate from the second to last day of the prior month, not a
transaction date rate or suitable weighted average, or another alternative. The current system does not
allow for the correct rate to be used.
Effect:
Foreign exchange translation methodology is currently not in accordance with accounting standards.
There are differences within the Plan Inc. financial statements that have been identified but not
corrected as a result of the foreign exchange translation methodology issues noted.
Recommendation:
As management plan, design and configure the new ERP system consideration should be given to the
need to input foreign exchange rates into the system on a daily basis to ensure compliance with the
accounting standards and Plan’s accounting policies.
Views of Responsible Officials and Management’s Corrective Action Plan:
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-003: Classification, completeness and accuracy of bank accounts (significant
deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23
Pass-through: All applicable
Criteria:
Accurate and reliable financial records, including listing of bank accounts and bank reconciliations,
are necessary to ensure that testing populations are complete, accurate and bank accounts are
correctly classified.
Condition:
Plan Inc. holds over 550 bank accounts between Global Hub, Plan Ltd and the Country Offices. The
following points were noted during the Plan Inc. financial statement audit:
1. From our testing performed over opening and closing bank accounts at the regional hub level, we
noted an account which was classified as closed prior to receiving a formal letter from the bank
confirming the closure. The account remains open with a balance of €36.
2. In the bank confirmation we independently received from ECO Bank Cameroon we noted two
additional bank account balances of €212k (immaterial and below de minimis reporting threshold)
which were not included in the general ledger.
3. During our testing, differences in bank account numbers were noted in several instances between
either bank confirmations / bank statements / bank reconciliations compared to the bank account
listing which reflected the old account numbers. This was the case for accounts at five banks across
different Country Offices (‘CO’).
4. During our testing, differences in bank account numbers were noted from three bank
reconciliations (GL180090, GL180080, and GL168060) compared to the bank account listing as a
result of typos made on the bank reconciliations. The account numbers per Plan Inc. bank account
listing for these accounts, however, was correct.
5. During our testing, it was noted that two bank reconciliations (GL168010 and GL168110) had
incorrect local currencies input into the bank reconciliation in the currency field. This had no financial
impact on the bank reconciliations performed.
6. For two GL accounts (GL168120 and GL168129) differences amounting to €693,984 between the
denominated balance in bank reconciliation and the denominated balance per trial balance were
noted. Plan confirmed the amount pertains to the revaluation of currency and that the account should
not be reevaluated in local currency. This is a system error due to the wrong set up of the monthly
revaluation process for these two specific GL accounts.
Cause:
For the first point, Plan had acted on the request to close the bank account when the request had been
acknowledged but before it had been confirmed, and therefore removed the account from the cash
listing despite a formal confirmation letter from the bank not being received.
For the second, the root cause of this issue is the CO not following the process in relation to opening
bank accounts and appropriately informing Regional Hub (‘RH’) and Global Hub (‘GH’).
For points three and four, the revised bank account numbers were not updated on the bank account
listing which still contained the old account numbers; and for point five the CO had not picked up the
incorrect currency field noted or incorrect bank account number following review of the
reconciliation.
For the sixth point, two GL accounts had an incorrect variant set up causing differences between the
bank reconciliation and the trial balance.
Effect:
Classifying balances as closed creates risks over the completeness of the bank account listing. There is
a risk that a large number of accounts are classified as closed despite still being open or an account
with a material cash balance could be excluded from the cash listing.
Not identifying and reporting bank accounts on a timely basis to GH and bank account numbers
inaccurately reflected on the bank account listing or bank reconciliations creates risks over the
completeness of the bank account listing.
Per the Bank Secrecy Act, Plan is required through FBAR ( Foreign Bank and Financial Accounts, US
Federal Government) to report all non-US bank accounts to the US in March each year. FBAR then
performs ad hoc checks of various entities and if Plan is found not reporting a full list of active
accounts, they will receive penalty fines for not complying with US requirements.
Incorrect currencies or account numbers reflected on the bank reconciliations and bank fees not
included creates risk over the completeness and accuracy of bank reconciliations.
Additionally, the incorrect application of the variants creates the risk of inaccuracies performed on the
foreign currency translation of bank accounts.
Recommendation:
We recommend the following:
Bank accounts are not classified as closed until a formal closure letter from the bank is received.
The RHs perform timely monthly reviews to ensure the completeness of bank accounts and COs are
reminded of the process around opening and closing bank accounts and the required notifications to
RH and GH.
Management put in place a process whereby appropriate review of bank details is performed at a CO
level during the year end FBAR process as reliance is placed by GH on what is reported by the Country
Offices.
Management update the bank account listing to reflect updated bank account numbers.
Management ensure COs review the bank reconciliations for accuracy of financial and non-financial
data (such as account numbers).
Management ensure the correct set up of the monthly revaluation process for bank related GL
accounts.
Views of Responsible Officials and Management’s Corrective Action Plan :
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-004: Foreign exchange translation methodology (repeat of prior year finding 2022-004, 2021-005, 2020-006, 2019-006) (significant deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23, FY22, FY21, FY20 and FY19
Pass-through: All applicable
Criteria:
Accurate and reliable financial records of many kinds are necessary to meet ongoing financial
reporting and operational needs and requirements. The rate of exchange used throughout any given
month is the spot rate from the second to last working day of the prior month. This is not therefore the
‘the rate of exchange ruling at the date of the transaction’ in accordance with the Plan Inc. accounting
policies as stated in the financial statements.
Condition:
For all transactions, the impact of exchange rates takes place in the following stages:
At a transaction level
1. Translation from document currency (i.e. currency of income/expense per invoice) to local
currency at the time of initial recognition
2. Local currency to functional currency (Euro)
3. Translation to actual rate at date of settlement
4. Translation of outstanding amounts within the balance sheet at the period end rate
At the consolidation level
5. Functional currency to reporting currency (USD)
We note the following:
The monthly rate used for consolidation purposes is also the spot rate from the second to last day of
the previous month and not an appropriate average rate as required and we have noted an immaterial
misstatement relating to the translation of I&E into the reporting currency (USD).
As the foreign exchange methodology is unchanged from the prior year, the matter therefore still
remains open in FY23.
In FY23 management performed a retrospective analysis to assess the misstatement caused by using
the incorrect foreign exchange rate. We have assessed this analysis and confirmed the completeness,
inputs and mathematical accuracy thereof. We have confirmed there is an immaterial misstatement
arising as a result of the effect of using the incorrect foreign exchange rates for income and
expenditure.
Cause:
The rates used, as noted above, are a spot rate from the second to last day of the prior month, not a
transaction date rate or suitable weighted average, or another alternative. The current system does not
allow for the correct rate to be used.
Effect:
Foreign exchange translation methodology is currently not in accordance with accounting standards.
There are differences within the Plan Inc. financial statements that have been identified but not
corrected as a result of the foreign exchange translation methodology issues noted.
Recommendation:
As management plan, design and configure the new ERP system consideration should be given to the
need to input foreign exchange rates into the system on a daily basis to ensure compliance with the
accounting standards and Plan’s accounting policies.
Views of Responsible Officials and Management’s Corrective Action Plan:
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-003: Classification, completeness and accuracy of bank accounts (significant
deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23
Pass-through: All applicable
Criteria:
Accurate and reliable financial records, including listing of bank accounts and bank reconciliations,
are necessary to ensure that testing populations are complete, accurate and bank accounts are
correctly classified.
Condition:
Plan Inc. holds over 550 bank accounts between Global Hub, Plan Ltd and the Country Offices. The
following points were noted during the Plan Inc. financial statement audit:
1. From our testing performed over opening and closing bank accounts at the regional hub level, we
noted an account which was classified as closed prior to receiving a formal letter from the bank
confirming the closure. The account remains open with a balance of €36.
2. In the bank confirmation we independently received from ECO Bank Cameroon we noted two
additional bank account balances of €212k (immaterial and below de minimis reporting threshold)
which were not included in the general ledger.
3. During our testing, differences in bank account numbers were noted in several instances between
either bank confirmations / bank statements / bank reconciliations compared to the bank account
listing which reflected the old account numbers. This was the case for accounts at five banks across
different Country Offices (‘CO’).
4. During our testing, differences in bank account numbers were noted from three bank
reconciliations (GL180090, GL180080, and GL168060) compared to the bank account listing as a
result of typos made on the bank reconciliations. The account numbers per Plan Inc. bank account
listing for these accounts, however, was correct.
5. During our testing, it was noted that two bank reconciliations (GL168010 and GL168110) had
incorrect local currencies input into the bank reconciliation in the currency field. This had no financial
impact on the bank reconciliations performed.
6. For two GL accounts (GL168120 and GL168129) differences amounting to €693,984 between the
denominated balance in bank reconciliation and the denominated balance per trial balance were
noted. Plan confirmed the amount pertains to the revaluation of currency and that the account should
not be reevaluated in local currency. This is a system error due to the wrong set up of the monthly
revaluation process for these two specific GL accounts.
Cause:
For the first point, Plan had acted on the request to close the bank account when the request had been
acknowledged but before it had been confirmed, and therefore removed the account from the cash
listing despite a formal confirmation letter from the bank not being received.
For the second, the root cause of this issue is the CO not following the process in relation to opening
bank accounts and appropriately informing Regional Hub (‘RH’) and Global Hub (‘GH’).
For points three and four, the revised bank account numbers were not updated on the bank account
listing which still contained the old account numbers; and for point five the CO had not picked up the
incorrect currency field noted or incorrect bank account number following review of the
reconciliation.
For the sixth point, two GL accounts had an incorrect variant set up causing differences between the
bank reconciliation and the trial balance.
Effect:
Classifying balances as closed creates risks over the completeness of the bank account listing. There is
a risk that a large number of accounts are classified as closed despite still being open or an account
with a material cash balance could be excluded from the cash listing.
Not identifying and reporting bank accounts on a timely basis to GH and bank account numbers
inaccurately reflected on the bank account listing or bank reconciliations creates risks over the
completeness of the bank account listing.
Per the Bank Secrecy Act, Plan is required through FBAR ( Foreign Bank and Financial Accounts, US
Federal Government) to report all non-US bank accounts to the US in March each year. FBAR then
performs ad hoc checks of various entities and if Plan is found not reporting a full list of active
accounts, they will receive penalty fines for not complying with US requirements.
Incorrect currencies or account numbers reflected on the bank reconciliations and bank fees not
included creates risk over the completeness and accuracy of bank reconciliations.
Additionally, the incorrect application of the variants creates the risk of inaccuracies performed on the
foreign currency translation of bank accounts.
Recommendation:
We recommend the following:
Bank accounts are not classified as closed until a formal closure letter from the bank is received.
The RHs perform timely monthly reviews to ensure the completeness of bank accounts and COs are
reminded of the process around opening and closing bank accounts and the required notifications to
RH and GH.
Management put in place a process whereby appropriate review of bank details is performed at a CO
level during the year end FBAR process as reliance is placed by GH on what is reported by the Country
Offices.
Management update the bank account listing to reflect updated bank account numbers.
Management ensure COs review the bank reconciliations for accuracy of financial and non-financial
data (such as account numbers).
Management ensure the correct set up of the monthly revaluation process for bank related GL
accounts.
Views of Responsible Officials and Management’s Corrective Action Plan :
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-004: Foreign exchange translation methodology (repeat of prior year finding 2022-004, 2021-005, 2020-006, 2019-006) (significant deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23, FY22, FY21, FY20 and FY19
Pass-through: All applicable
Criteria:
Accurate and reliable financial records of many kinds are necessary to meet ongoing financial
reporting and operational needs and requirements. The rate of exchange used throughout any given
month is the spot rate from the second to last working day of the prior month. This is not therefore the
‘the rate of exchange ruling at the date of the transaction’ in accordance with the Plan Inc. accounting
policies as stated in the financial statements.
Condition:
For all transactions, the impact of exchange rates takes place in the following stages:
At a transaction level
1. Translation from document currency (i.e. currency of income/expense per invoice) to local
currency at the time of initial recognition
2. Local currency to functional currency (Euro)
3. Translation to actual rate at date of settlement
4. Translation of outstanding amounts within the balance sheet at the period end rate
At the consolidation level
5. Functional currency to reporting currency (USD)
We note the following:
The monthly rate used for consolidation purposes is also the spot rate from the second to last day of
the previous month and not an appropriate average rate as required and we have noted an immaterial
misstatement relating to the translation of I&E into the reporting currency (USD).
As the foreign exchange methodology is unchanged from the prior year, the matter therefore still
remains open in FY23.
In FY23 management performed a retrospective analysis to assess the misstatement caused by using
the incorrect foreign exchange rate. We have assessed this analysis and confirmed the completeness,
inputs and mathematical accuracy thereof. We have confirmed there is an immaterial misstatement
arising as a result of the effect of using the incorrect foreign exchange rates for income and
expenditure.
Cause:
The rates used, as noted above, are a spot rate from the second to last day of the prior month, not a
transaction date rate or suitable weighted average, or another alternative. The current system does not
allow for the correct rate to be used.
Effect:
Foreign exchange translation methodology is currently not in accordance with accounting standards.
There are differences within the Plan Inc. financial statements that have been identified but not
corrected as a result of the foreign exchange translation methodology issues noted.
Recommendation:
As management plan, design and configure the new ERP system consideration should be given to the
need to input foreign exchange rates into the system on a daily basis to ensure compliance with the
accounting standards and Plan’s accounting policies.
Views of Responsible Officials and Management’s Corrective Action Plan:
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-003: Classification, completeness and accuracy of bank accounts (significant
deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23
Pass-through: All applicable
Criteria:
Accurate and reliable financial records, including listing of bank accounts and bank reconciliations,
are necessary to ensure that testing populations are complete, accurate and bank accounts are
correctly classified.
Condition:
Plan Inc. holds over 550 bank accounts between Global Hub, Plan Ltd and the Country Offices. The
following points were noted during the Plan Inc. financial statement audit:
1. From our testing performed over opening and closing bank accounts at the regional hub level, we
noted an account which was classified as closed prior to receiving a formal letter from the bank
confirming the closure. The account remains open with a balance of €36.
2. In the bank confirmation we independently received from ECO Bank Cameroon we noted two
additional bank account balances of €212k (immaterial and below de minimis reporting threshold)
which were not included in the general ledger.
3. During our testing, differences in bank account numbers were noted in several instances between
either bank confirmations / bank statements / bank reconciliations compared to the bank account
listing which reflected the old account numbers. This was the case for accounts at five banks across
different Country Offices (‘CO’).
4. During our testing, differences in bank account numbers were noted from three bank
reconciliations (GL180090, GL180080, and GL168060) compared to the bank account listing as a
result of typos made on the bank reconciliations. The account numbers per Plan Inc. bank account
listing for these accounts, however, was correct.
5. During our testing, it was noted that two bank reconciliations (GL168010 and GL168110) had
incorrect local currencies input into the bank reconciliation in the currency field. This had no financial
impact on the bank reconciliations performed.
6. For two GL accounts (GL168120 and GL168129) differences amounting to €693,984 between the
denominated balance in bank reconciliation and the denominated balance per trial balance were
noted. Plan confirmed the amount pertains to the revaluation of currency and that the account should
not be reevaluated in local currency. This is a system error due to the wrong set up of the monthly
revaluation process for these two specific GL accounts.
Cause:
For the first point, Plan had acted on the request to close the bank account when the request had been
acknowledged but before it had been confirmed, and therefore removed the account from the cash
listing despite a formal confirmation letter from the bank not being received.
For the second, the root cause of this issue is the CO not following the process in relation to opening
bank accounts and appropriately informing Regional Hub (‘RH’) and Global Hub (‘GH’).
For points three and four, the revised bank account numbers were not updated on the bank account
listing which still contained the old account numbers; and for point five the CO had not picked up the
incorrect currency field noted or incorrect bank account number following review of the
reconciliation.
For the sixth point, two GL accounts had an incorrect variant set up causing differences between the
bank reconciliation and the trial balance.
Effect:
Classifying balances as closed creates risks over the completeness of the bank account listing. There is
a risk that a large number of accounts are classified as closed despite still being open or an account
with a material cash balance could be excluded from the cash listing.
Not identifying and reporting bank accounts on a timely basis to GH and bank account numbers
inaccurately reflected on the bank account listing or bank reconciliations creates risks over the
completeness of the bank account listing.
Per the Bank Secrecy Act, Plan is required through FBAR ( Foreign Bank and Financial Accounts, US
Federal Government) to report all non-US bank accounts to the US in March each year. FBAR then
performs ad hoc checks of various entities and if Plan is found not reporting a full list of active
accounts, they will receive penalty fines for not complying with US requirements.
Incorrect currencies or account numbers reflected on the bank reconciliations and bank fees not
included creates risk over the completeness and accuracy of bank reconciliations.
Additionally, the incorrect application of the variants creates the risk of inaccuracies performed on the
foreign currency translation of bank accounts.
Recommendation:
We recommend the following:
Bank accounts are not classified as closed until a formal closure letter from the bank is received.
The RHs perform timely monthly reviews to ensure the completeness of bank accounts and COs are
reminded of the process around opening and closing bank accounts and the required notifications to
RH and GH.
Management put in place a process whereby appropriate review of bank details is performed at a CO
level during the year end FBAR process as reliance is placed by GH on what is reported by the Country
Offices.
Management update the bank account listing to reflect updated bank account numbers.
Management ensure COs review the bank reconciliations for accuracy of financial and non-financial
data (such as account numbers).
Management ensure the correct set up of the monthly revaluation process for bank related GL
accounts.
Views of Responsible Officials and Management’s Corrective Action Plan :
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-004: Foreign exchange translation methodology (repeat of prior year finding 2022-004, 2021-005, 2020-006, 2019-006) (significant deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23, FY22, FY21, FY20 and FY19
Pass-through: All applicable
Criteria:
Accurate and reliable financial records of many kinds are necessary to meet ongoing financial
reporting and operational needs and requirements. The rate of exchange used throughout any given
month is the spot rate from the second to last working day of the prior month. This is not therefore the
‘the rate of exchange ruling at the date of the transaction’ in accordance with the Plan Inc. accounting
policies as stated in the financial statements.
Condition:
For all transactions, the impact of exchange rates takes place in the following stages:
At a transaction level
1. Translation from document currency (i.e. currency of income/expense per invoice) to local
currency at the time of initial recognition
2. Local currency to functional currency (Euro)
3. Translation to actual rate at date of settlement
4. Translation of outstanding amounts within the balance sheet at the period end rate
At the consolidation level
5. Functional currency to reporting currency (USD)
We note the following:
The monthly rate used for consolidation purposes is also the spot rate from the second to last day of
the previous month and not an appropriate average rate as required and we have noted an immaterial
misstatement relating to the translation of I&E into the reporting currency (USD).
As the foreign exchange methodology is unchanged from the prior year, the matter therefore still
remains open in FY23.
In FY23 management performed a retrospective analysis to assess the misstatement caused by using
the incorrect foreign exchange rate. We have assessed this analysis and confirmed the completeness,
inputs and mathematical accuracy thereof. We have confirmed there is an immaterial misstatement
arising as a result of the effect of using the incorrect foreign exchange rates for income and
expenditure.
Cause:
The rates used, as noted above, are a spot rate from the second to last day of the prior month, not a
transaction date rate or suitable weighted average, or another alternative. The current system does not
allow for the correct rate to be used.
Effect:
Foreign exchange translation methodology is currently not in accordance with accounting standards.
There are differences within the Plan Inc. financial statements that have been identified but not
corrected as a result of the foreign exchange translation methodology issues noted.
Recommendation:
As management plan, design and configure the new ERP system consideration should be given to the
need to input foreign exchange rates into the system on a daily basis to ensure compliance with the
accounting standards and Plan’s accounting policies.
Views of Responsible Officials and Management’s Corrective Action Plan:
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-003: Classification, completeness and accuracy of bank accounts (significant
deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23
Pass-through: All applicable
Criteria:
Accurate and reliable financial records, including listing of bank accounts and bank reconciliations,
are necessary to ensure that testing populations are complete, accurate and bank accounts are
correctly classified.
Condition:
Plan Inc. holds over 550 bank accounts between Global Hub, Plan Ltd and the Country Offices. The
following points were noted during the Plan Inc. financial statement audit:
1. From our testing performed over opening and closing bank accounts at the regional hub level, we
noted an account which was classified as closed prior to receiving a formal letter from the bank
confirming the closure. The account remains open with a balance of €36.
2. In the bank confirmation we independently received from ECO Bank Cameroon we noted two
additional bank account balances of €212k (immaterial and below de minimis reporting threshold)
which were not included in the general ledger.
3. During our testing, differences in bank account numbers were noted in several instances between
either bank confirmations / bank statements / bank reconciliations compared to the bank account
listing which reflected the old account numbers. This was the case for accounts at five banks across
different Country Offices (‘CO’).
4. During our testing, differences in bank account numbers were noted from three bank
reconciliations (GL180090, GL180080, and GL168060) compared to the bank account listing as a
result of typos made on the bank reconciliations. The account numbers per Plan Inc. bank account
listing for these accounts, however, was correct.
5. During our testing, it was noted that two bank reconciliations (GL168010 and GL168110) had
incorrect local currencies input into the bank reconciliation in the currency field. This had no financial
impact on the bank reconciliations performed.
6. For two GL accounts (GL168120 and GL168129) differences amounting to €693,984 between the
denominated balance in bank reconciliation and the denominated balance per trial balance were
noted. Plan confirmed the amount pertains to the revaluation of currency and that the account should
not be reevaluated in local currency. This is a system error due to the wrong set up of the monthly
revaluation process for these two specific GL accounts.
Cause:
For the first point, Plan had acted on the request to close the bank account when the request had been
acknowledged but before it had been confirmed, and therefore removed the account from the cash
listing despite a formal confirmation letter from the bank not being received.
For the second, the root cause of this issue is the CO not following the process in relation to opening
bank accounts and appropriately informing Regional Hub (‘RH’) and Global Hub (‘GH’).
For points three and four, the revised bank account numbers were not updated on the bank account
listing which still contained the old account numbers; and for point five the CO had not picked up the
incorrect currency field noted or incorrect bank account number following review of the
reconciliation.
For the sixth point, two GL accounts had an incorrect variant set up causing differences between the
bank reconciliation and the trial balance.
Effect:
Classifying balances as closed creates risks over the completeness of the bank account listing. There is
a risk that a large number of accounts are classified as closed despite still being open or an account
with a material cash balance could be excluded from the cash listing.
Not identifying and reporting bank accounts on a timely basis to GH and bank account numbers
inaccurately reflected on the bank account listing or bank reconciliations creates risks over the
completeness of the bank account listing.
Per the Bank Secrecy Act, Plan is required through FBAR ( Foreign Bank and Financial Accounts, US
Federal Government) to report all non-US bank accounts to the US in March each year. FBAR then
performs ad hoc checks of various entities and if Plan is found not reporting a full list of active
accounts, they will receive penalty fines for not complying with US requirements.
Incorrect currencies or account numbers reflected on the bank reconciliations and bank fees not
included creates risk over the completeness and accuracy of bank reconciliations.
Additionally, the incorrect application of the variants creates the risk of inaccuracies performed on the
foreign currency translation of bank accounts.
Recommendation:
We recommend the following:
Bank accounts are not classified as closed until a formal closure letter from the bank is received.
The RHs perform timely monthly reviews to ensure the completeness of bank accounts and COs are
reminded of the process around opening and closing bank accounts and the required notifications to
RH and GH.
Management put in place a process whereby appropriate review of bank details is performed at a CO
level during the year end FBAR process as reliance is placed by GH on what is reported by the Country
Offices.
Management update the bank account listing to reflect updated bank account numbers.
Management ensure COs review the bank reconciliations for accuracy of financial and non-financial
data (such as account numbers).
Management ensure the correct set up of the monthly revaluation process for bank related GL
accounts.
Views of Responsible Officials and Management’s Corrective Action Plan :
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.
Ref 2023-004: Foreign exchange translation methodology (repeat of prior year finding 2022-004, 2021-005, 2020-006, 2019-006) (significant deficiency)
Federal Agency: All
Program: All
Assistance Listing: All
Award #: All
Award year: FY23, FY22, FY21, FY20 and FY19
Pass-through: All applicable
Criteria:
Accurate and reliable financial records of many kinds are necessary to meet ongoing financial
reporting and operational needs and requirements. The rate of exchange used throughout any given
month is the spot rate from the second to last working day of the prior month. This is not therefore the
‘the rate of exchange ruling at the date of the transaction’ in accordance with the Plan Inc. accounting
policies as stated in the financial statements.
Condition:
For all transactions, the impact of exchange rates takes place in the following stages:
At a transaction level
1. Translation from document currency (i.e. currency of income/expense per invoice) to local
currency at the time of initial recognition
2. Local currency to functional currency (Euro)
3. Translation to actual rate at date of settlement
4. Translation of outstanding amounts within the balance sheet at the period end rate
At the consolidation level
5. Functional currency to reporting currency (USD)
We note the following:
The monthly rate used for consolidation purposes is also the spot rate from the second to last day of
the previous month and not an appropriate average rate as required and we have noted an immaterial
misstatement relating to the translation of I&E into the reporting currency (USD).
As the foreign exchange methodology is unchanged from the prior year, the matter therefore still
remains open in FY23.
In FY23 management performed a retrospective analysis to assess the misstatement caused by using
the incorrect foreign exchange rate. We have assessed this analysis and confirmed the completeness,
inputs and mathematical accuracy thereof. We have confirmed there is an immaterial misstatement
arising as a result of the effect of using the incorrect foreign exchange rates for income and
expenditure.
Cause:
The rates used, as noted above, are a spot rate from the second to last day of the prior month, not a
transaction date rate or suitable weighted average, or another alternative. The current system does not
allow for the correct rate to be used.
Effect:
Foreign exchange translation methodology is currently not in accordance with accounting standards.
There are differences within the Plan Inc. financial statements that have been identified but not
corrected as a result of the foreign exchange translation methodology issues noted.
Recommendation:
As management plan, design and configure the new ERP system consideration should be given to the
need to input foreign exchange rates into the system on a daily basis to ensure compliance with the
accounting standards and Plan’s accounting policies.
Views of Responsible Officials and Management’s Corrective Action Plan:
Views of responsible officials and management’s corrective action plan are included at the
end of this report after the summary schedule of prior audit findings and status.