Audit 299718

FY End
2023-06-30
Total Expended
$13.34M
Findings
112
Programs
5
Organization: Plan International Inc. (NY)
Year: 2023 Accepted: 2024-03-28

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
387600 2023-003 Significant Deficiency - ABCEFGHIJLMN
387601 2023-004 Significant Deficiency Yes ABCEFGHIJLMN
387602 2023-003 Significant Deficiency - ABCEFGHIJLMN
387603 2023-004 Significant Deficiency Yes ABCEFGHIJLMN
387604 2023-003 Significant Deficiency - ABCEFGHIJLMN
387605 2023-004 Significant Deficiency Yes ABCEFGHIJLMN
387606 2023-006 - - I
387607 2023-003 Significant Deficiency - ABCEFGHIJLMN
387608 2023-004 Significant Deficiency Yes ABCEFGHIJLMN
387609 2023-003 Significant Deficiency - ABCEFGHIJLMN
387610 2023-004 Significant Deficiency Yes ABCEFGHIJLMN
387611 2023-007 - - I
387612 2023-003 Significant Deficiency - ABCEFGHIJLMN
387613 2023-004 Significant Deficiency Yes ABCEFGHIJLMN
387614 2023-003 Significant Deficiency - ABCEFGHIJLMN
387615 2023-004 Significant Deficiency Yes ABCEFGHIJLMN
387616 2023-003 Significant Deficiency - ABCEFGHIJLMN
387617 2023-004 Significant Deficiency Yes ABCEFGHIJLMN
387618 2023-003 Significant Deficiency - ABCEFGHIJLMN
387619 2023-004 Significant Deficiency Yes ABCEFGHIJLMN
387620 2023-003 Significant Deficiency - ABCEFGHIJLMN
387621 2023-004 Significant Deficiency Yes ABCEFGHIJLMN
387622 2023-003 Significant Deficiency - ABCEFGHIJLMN
387623 2023-004 Significant Deficiency Yes ABCEFGHIJLMN
387624 2023-003 Significant Deficiency - ABCEFGHIJLMN
387625 2023-004 Significant Deficiency Yes ABCEFGHIJLMN
387626 2023-003 Significant Deficiency - ABCEFGHIJLMN
387627 2023-004 Significant Deficiency Yes ABCEFGHIJLMN
387628 2023-003 Significant Deficiency - ABCEFGHIJLMN
387629 2023-004 Significant Deficiency Yes ABCEFGHIJLMN
387630 2023-003 Significant Deficiency - ABCEFGHIJLMN
387631 2023-004 Significant Deficiency Yes ABCEFGHIJLMN
387632 2023-003 Significant Deficiency - ABCEFGHIJLMN
387633 2023-004 Significant Deficiency Yes ABCEFGHIJLMN
387634 2023-003 Significant Deficiency - ABCEFGHIJLMN
387635 2023-004 Significant Deficiency Yes ABCEFGHIJLMN
387636 2023-003 Significant Deficiency - ABCEFGHIJLMN
387637 2023-004 Significant Deficiency Yes ABCEFGHIJLMN
387638 2023-003 Significant Deficiency - ABCEFGHIJLMN
387639 2023-004 Significant Deficiency Yes ABCEFGHIJLMN
387640 2023-003 Significant Deficiency - ABCEFGHIJLMN
387641 2023-004 Significant Deficiency Yes ABCEFGHIJLMN
387642 2023-007 - - I
387643 2023-003 Significant Deficiency - ABCEFGHIJLMN
387644 2023-004 Significant Deficiency Yes ABCEFGHIJLMN
387645 2023-007 - - I
387646 2023-003 Significant Deficiency - ABCEFGHIJLMN
387647 2023-004 Significant Deficiency Yes ABCEFGHIJLMN
387648 2023-003 Significant Deficiency - ABCEFGHIJLMN
387649 2023-004 Significant Deficiency Yes ABCEFGHIJLMN
387650 2023-003 Significant Deficiency - ABCEFGHIJLMN
387651 2023-004 Significant Deficiency Yes ABCEFGHIJLMN
387652 2023-003 Significant Deficiency - ABCEFGHIJLMN
387653 2023-004 Significant Deficiency Yes ABCEFGHIJLMN
387654 2023-003 Significant Deficiency - ABCEFGHIJLMN
387655 2023-004 Significant Deficiency Yes ABCEFGHIJLMN
964042 2023-003 Significant Deficiency - ABCEFGHIJLMN
964043 2023-004 Significant Deficiency Yes ABCEFGHIJLMN
964044 2023-003 Significant Deficiency - ABCEFGHIJLMN
964045 2023-004 Significant Deficiency Yes ABCEFGHIJLMN
964046 2023-003 Significant Deficiency - ABCEFGHIJLMN
964047 2023-004 Significant Deficiency Yes ABCEFGHIJLMN
964048 2023-006 - - I
964049 2023-003 Significant Deficiency - ABCEFGHIJLMN
964050 2023-004 Significant Deficiency Yes ABCEFGHIJLMN
964051 2023-003 Significant Deficiency - ABCEFGHIJLMN
964052 2023-004 Significant Deficiency Yes ABCEFGHIJLMN
964053 2023-007 - - I
964054 2023-003 Significant Deficiency - ABCEFGHIJLMN
964055 2023-004 Significant Deficiency Yes ABCEFGHIJLMN
964056 2023-003 Significant Deficiency - ABCEFGHIJLMN
964057 2023-004 Significant Deficiency Yes ABCEFGHIJLMN
964058 2023-003 Significant Deficiency - ABCEFGHIJLMN
964059 2023-004 Significant Deficiency Yes ABCEFGHIJLMN
964060 2023-003 Significant Deficiency - ABCEFGHIJLMN
964061 2023-004 Significant Deficiency Yes ABCEFGHIJLMN
964062 2023-003 Significant Deficiency - ABCEFGHIJLMN
964063 2023-004 Significant Deficiency Yes ABCEFGHIJLMN
964064 2023-003 Significant Deficiency - ABCEFGHIJLMN
964065 2023-004 Significant Deficiency Yes ABCEFGHIJLMN
964066 2023-003 Significant Deficiency - ABCEFGHIJLMN
964067 2023-004 Significant Deficiency Yes ABCEFGHIJLMN
964068 2023-003 Significant Deficiency - ABCEFGHIJLMN
964069 2023-004 Significant Deficiency Yes ABCEFGHIJLMN
964070 2023-003 Significant Deficiency - ABCEFGHIJLMN
964071 2023-004 Significant Deficiency Yes ABCEFGHIJLMN
964072 2023-003 Significant Deficiency - ABCEFGHIJLMN
964073 2023-004 Significant Deficiency Yes ABCEFGHIJLMN
964074 2023-003 Significant Deficiency - ABCEFGHIJLMN
964075 2023-004 Significant Deficiency Yes ABCEFGHIJLMN
964076 2023-003 Significant Deficiency - ABCEFGHIJLMN
964077 2023-004 Significant Deficiency Yes ABCEFGHIJLMN
964078 2023-003 Significant Deficiency - ABCEFGHIJLMN
964079 2023-004 Significant Deficiency Yes ABCEFGHIJLMN
964080 2023-003 Significant Deficiency - ABCEFGHIJLMN
964081 2023-004 Significant Deficiency Yes ABCEFGHIJLMN
964082 2023-003 Significant Deficiency - ABCEFGHIJLMN
964083 2023-004 Significant Deficiency Yes ABCEFGHIJLMN
964084 2023-007 - - I
964085 2023-003 Significant Deficiency - ABCEFGHIJLMN
964086 2023-004 Significant Deficiency Yes ABCEFGHIJLMN
964087 2023-007 - - I
964088 2023-003 Significant Deficiency - ABCEFGHIJLMN
964089 2023-004 Significant Deficiency Yes ABCEFGHIJLMN
964090 2023-003 Significant Deficiency - ABCEFGHIJLMN
964091 2023-004 Significant Deficiency Yes ABCEFGHIJLMN
964092 2023-003 Significant Deficiency - ABCEFGHIJLMN
964093 2023-004 Significant Deficiency Yes ABCEFGHIJLMN
964094 2023-003 Significant Deficiency - ABCEFGHIJLMN
964095 2023-004 Significant Deficiency Yes ABCEFGHIJLMN
964096 2023-003 Significant Deficiency - ABCEFGHIJLMN
964097 2023-004 Significant Deficiency Yes ABCEFGHIJLMN

Programs

ALN Program Spent Major Findings
10.608 Food for Education $1.08M Yes 2
19.019 International Programs to Combat Human Trafficking $298,150 - 2
19.517 Overseas Refugee Assistance Programs for Africa $210,755 Yes 3
17.401 International Labor Programs $183,493 - 2
98.001 Usaid Foreign Assistance for Programs Overseas $319 - 2

Contacts

Name Title Type
UTDAK8JTBZ78 Celine Thibaut Auditee
4015628421 Sandeep Dhillon Auditor
No contacts on file

Notes to SEFA

Title: Summary of significant accounting policies Accounting Policies: The accompanying Schedule of Expenditures of Federal Awards (the “Schedule”) has been prepared for the purpose of presenting a summary of the federal award expenditures of Plan International Inc. (the “Company” or “Plan” or “Plan Inc.”) for the year ended June 30, 2023. Since the Schedule presents only a selected portion of the activities of Plan, it is not intended to, and does not present the financial position, changes in net assets or cash flows of Plan. ALN numbers (Assistance listing numbers) and pass-through numbers are provided when available. De Minimis Rate Used: N Rate Explanation: Plan does not use the 10% de minimis cost rate allowed by section 200.414 of Uniform Guidance when charging indirect costs to the U.S. Federal Awards. Plan does not charge an indirect cost rate. The accounting principles followed by Plan in preparing the accompanying Schedule are as follows:Expenditures are recognized as incurred using the accrual method of accounting.Plan does not use the 10% de minimis cost rate allowed by section 200.414 of Uniform Guidance when charging indirect cost to the U.S. Federal Awards. Plan does not charge indirect costs to federal awards.Plan International USA, Inc. is a related party of Plan International, Inc. and provides all of Plan International, Inc.s federal funding.
Title: Subrecipients Accounting Policies: The accompanying Schedule of Expenditures of Federal Awards (the “Schedule”) has been prepared for the purpose of presenting a summary of the federal award expenditures of Plan International Inc. (the “Company” or “Plan” or “Plan Inc.”) for the year ended June 30, 2023. Since the Schedule presents only a selected portion of the activities of Plan, it is not intended to, and does not present the financial position, changes in net assets or cash flows of Plan. ALN numbers (Assistance listing numbers) and pass-through numbers are provided when available. De Minimis Rate Used: N Rate Explanation: Plan does not use the 10% de minimis cost rate allowed by section 200.414 of Uniform Guidance when charging indirect costs to the U.S. Federal Awards. Plan does not charge an indirect cost rate. Plan may contract with a subrecipient to carry out certain functions under federally sponsored programs. Plan does not advance any U.S. Government funds to subrecipients. Plan only claims reimbursement for subrecipient spend once the subrecipient has incurred the expenditure and performed the relevant activity. It is at this point that the subrecipient expenditure is included on the Schedule of Expenditures of Federal Awards.

Finding Details

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.