FAC Explorer

Audit 300993

FY End
2023-06-30
Total Expended
$4.64M
Findings
8
Programs
2
Organization: Invisible Children, Inc. (DC)
Year: 2023 Accepted: 2024-03-29
Auditor: Gelman Rosenberg & Freedman

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
390105 2023-001 Significant Deficiency Yes L
390106 2023-002 Significant Deficiency - I
390107 2023-001 Significant Deficiency Yes L
390108 2023-002 Significant Deficiency - I
966547 2023-001 Significant Deficiency Yes L
966548 2023-002 Significant Deficiency - I
966549 2023-001 Significant Deficiency Yes L
966550 2023-002 Significant Deficiency - I

Programs

ALN Program Spent Major Findings
98.001 Usaid Foreign Assistance for Programs Overseas $1.40M - 0
19.345 International Programs to Support Democracy, Human Rights and Labor $863,646 Yes 2

Contacts

Name Title Type
KS56JLF7KH43 Erin Miller Auditee
6195622799 Lindsay Dean Auditor
No contacts on file

Notes to SEFA

Title: Note 1. Basis of Presentation Accounting Policies: Expenditures on the Schedule are reported on the accrual basis of accounting. De Minimis Rate Used: N Rate Explanation: Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the Schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. The Organization has elected not to use the 10-percent de minimis indirect cost rate as allowed under the Uniform Guidance. The accompanying Schedule of Expenditures of Federal Awards (the Schedule) includes the Federal award activity of the Organization under programs of the United States Government for the year ended June 30, 2023. Information on the Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). The Schedule presents only a selected portion of the operations of the Organization; accordingly, it is not intended to and does not present the financial position, change in net assets or cash flows of the Organization.
Title: Note 2. Summary of Significant Accounting Policies Accounting Policies: Expenditures on the Schedule are reported on the accrual basis of accounting. De Minimis Rate Used: N Rate Explanation: Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the Schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. The Organization has elected not to use the 10-percent de minimis indirect cost rate as allowed under the Uniform Guidance. Expenditures on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the Schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. The Organization has elected not to use the 10-percent de minimis indirect cost rate as allowed under the Uniform Guidance.

Finding Details

Finding 2023-001
Finding 2023-001: Federal Funding Accountability and Transparency Act Subaward Reporting Information of the Federal Program: Assistance Listing Number 19.345 Criteria: As noted in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements who make first tier subawards of $30,000 or more are required to register in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) and report subaward data through FSRS. Condition: The Organization did not register its subawards in the Federal Funding Accountability and Transparency Act Subaward Reporting System. Cause: The Organization did not update its financial and accounting policies, and as a result did not adhere to the guidance. Effect or Potential Effect: The Organization could inadvertently fail to ensure that subrecipients are in compliance with Federal award agency regulations.Questioned Costs: None noted Context: The Organization did not register their subawards in excess of $30,000 with the Federal Funding Accountability and Transparency Act Subaward Reporting System. Identification as a Repeat Finding, if Applicable: 2022-001 Recommendation: We recommend that the Organization update its policies and procedures to ensure all first tier subawards in excess of $30,000 are accurately and timely registered with the Federal Funding Accountability and Transparency Act Subaward Reporting System. In addition, the Organization should ensure any subawards are reported within the required time-frame.
Finding 2023-002
Finding 2023-002: Procurement Information of the Federal Program: Assistance Listing Number 19.345 Criteria: CFR 200.318 states that non-Federal entities must have and use documented procurement procedures consistent with the requirements for procurement regulations included in paragraphs 318 through 327. Condition: The Organization did not provide supporting documentation for certain procurement decisions, and we noted instances where a memo was used to justify noncompetitive procurement when it was not clearly justified by one of the reasons permitted within CFR 200.320:  The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold;  The item is available only from a single source;  The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation;  The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity;  After solicitation of a number of sources, competition is determined inadequate. Cause: The Organization has a procedure in place to ensure all vendors or suppliers paid with Federal funding are engaged in compliance with the Federal regulations but compliance with the policy was not always documented. Effect or Potential Effect: The Organization may have disallowed costs for not properly procuring goods or services. Questioned Costs: None noted Context: The Organization is at risk of entering into contracts for goods or services under Federal awards that were not adequately procured based on the regulations in the Uniform Guidance and the awarding agency could disallow the costs paid for the goods or services. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend that the Organization update its policies and procedures to ensure compliance with CFR 200.320 regarding noncompetitive procurement. In addition, we recommend that documentation be maintained for all procurement decisions in accordance with established policy.
Finding 2023-001
Finding 2023-001: Federal Funding Accountability and Transparency Act Subaward Reporting Information of the Federal Program: Assistance Listing Number 19.345 Criteria: As noted in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements who make first tier subawards of $30,000 or more are required to register in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) and report subaward data through FSRS. Condition: The Organization did not register its subawards in the Federal Funding Accountability and Transparency Act Subaward Reporting System. Cause: The Organization did not update its financial and accounting policies, and as a result did not adhere to the guidance. Effect or Potential Effect: The Organization could inadvertently fail to ensure that subrecipients are in compliance with Federal award agency regulations.Questioned Costs: None noted Context: The Organization did not register their subawards in excess of $30,000 with the Federal Funding Accountability and Transparency Act Subaward Reporting System. Identification as a Repeat Finding, if Applicable: 2022-001 Recommendation: We recommend that the Organization update its policies and procedures to ensure all first tier subawards in excess of $30,000 are accurately and timely registered with the Federal Funding Accountability and Transparency Act Subaward Reporting System. In addition, the Organization should ensure any subawards are reported within the required time-frame.
Finding 2023-002
Finding 2023-002: Procurement Information of the Federal Program: Assistance Listing Number 19.345 Criteria: CFR 200.318 states that non-Federal entities must have and use documented procurement procedures consistent with the requirements for procurement regulations included in paragraphs 318 through 327. Condition: The Organization did not provide supporting documentation for certain procurement decisions, and we noted instances where a memo was used to justify noncompetitive procurement when it was not clearly justified by one of the reasons permitted within CFR 200.320:  The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold;  The item is available only from a single source;  The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation;  The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity;  After solicitation of a number of sources, competition is determined inadequate. Cause: The Organization has a procedure in place to ensure all vendors or suppliers paid with Federal funding are engaged in compliance with the Federal regulations but compliance with the policy was not always documented. Effect or Potential Effect: The Organization may have disallowed costs for not properly procuring goods or services. Questioned Costs: None noted Context: The Organization is at risk of entering into contracts for goods or services under Federal awards that were not adequately procured based on the regulations in the Uniform Guidance and the awarding agency could disallow the costs paid for the goods or services. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend that the Organization update its policies and procedures to ensure compliance with CFR 200.320 regarding noncompetitive procurement. In addition, we recommend that documentation be maintained for all procurement decisions in accordance with established policy.
Finding 2023-001
Finding 2023-001: Federal Funding Accountability and Transparency Act Subaward Reporting Information of the Federal Program: Assistance Listing Number 19.345 Criteria: As noted in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements who make first tier subawards of $30,000 or more are required to register in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) and report subaward data through FSRS. Condition: The Organization did not register its subawards in the Federal Funding Accountability and Transparency Act Subaward Reporting System. Cause: The Organization did not update its financial and accounting policies, and as a result did not adhere to the guidance. Effect or Potential Effect: The Organization could inadvertently fail to ensure that subrecipients are in compliance with Federal award agency regulations.Questioned Costs: None noted Context: The Organization did not register their subawards in excess of $30,000 with the Federal Funding Accountability and Transparency Act Subaward Reporting System. Identification as a Repeat Finding, if Applicable: 2022-001 Recommendation: We recommend that the Organization update its policies and procedures to ensure all first tier subawards in excess of $30,000 are accurately and timely registered with the Federal Funding Accountability and Transparency Act Subaward Reporting System. In addition, the Organization should ensure any subawards are reported within the required time-frame.
Finding 2023-002
Finding 2023-002: Procurement Information of the Federal Program: Assistance Listing Number 19.345 Criteria: CFR 200.318 states that non-Federal entities must have and use documented procurement procedures consistent with the requirements for procurement regulations included in paragraphs 318 through 327. Condition: The Organization did not provide supporting documentation for certain procurement decisions, and we noted instances where a memo was used to justify noncompetitive procurement when it was not clearly justified by one of the reasons permitted within CFR 200.320:  The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold;  The item is available only from a single source;  The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation;  The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity;  After solicitation of a number of sources, competition is determined inadequate. Cause: The Organization has a procedure in place to ensure all vendors or suppliers paid with Federal funding are engaged in compliance with the Federal regulations but compliance with the policy was not always documented. Effect or Potential Effect: The Organization may have disallowed costs for not properly procuring goods or services. Questioned Costs: None noted Context: The Organization is at risk of entering into contracts for goods or services under Federal awards that were not adequately procured based on the regulations in the Uniform Guidance and the awarding agency could disallow the costs paid for the goods or services. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend that the Organization update its policies and procedures to ensure compliance with CFR 200.320 regarding noncompetitive procurement. In addition, we recommend that documentation be maintained for all procurement decisions in accordance with established policy.
Finding 2023-001
Finding 2023-001: Federal Funding Accountability and Transparency Act Subaward Reporting Information of the Federal Program: Assistance Listing Number 19.345 Criteria: As noted in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements who make first tier subawards of $30,000 or more are required to register in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) and report subaward data through FSRS. Condition: The Organization did not register its subawards in the Federal Funding Accountability and Transparency Act Subaward Reporting System. Cause: The Organization did not update its financial and accounting policies, and as a result did not adhere to the guidance. Effect or Potential Effect: The Organization could inadvertently fail to ensure that subrecipients are in compliance with Federal award agency regulations.Questioned Costs: None noted Context: The Organization did not register their subawards in excess of $30,000 with the Federal Funding Accountability and Transparency Act Subaward Reporting System. Identification as a Repeat Finding, if Applicable: 2022-001 Recommendation: We recommend that the Organization update its policies and procedures to ensure all first tier subawards in excess of $30,000 are accurately and timely registered with the Federal Funding Accountability and Transparency Act Subaward Reporting System. In addition, the Organization should ensure any subawards are reported within the required time-frame.
Finding 2023-002
Finding 2023-002: Procurement Information of the Federal Program: Assistance Listing Number 19.345 Criteria: CFR 200.318 states that non-Federal entities must have and use documented procurement procedures consistent with the requirements for procurement regulations included in paragraphs 318 through 327. Condition: The Organization did not provide supporting documentation for certain procurement decisions, and we noted instances where a memo was used to justify noncompetitive procurement when it was not clearly justified by one of the reasons permitted within CFR 200.320:  The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold;  The item is available only from a single source;  The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation;  The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity;  After solicitation of a number of sources, competition is determined inadequate. Cause: The Organization has a procedure in place to ensure all vendors or suppliers paid with Federal funding are engaged in compliance with the Federal regulations but compliance with the policy was not always documented. Effect or Potential Effect: The Organization may have disallowed costs for not properly procuring goods or services. Questioned Costs: None noted Context: The Organization is at risk of entering into contracts for goods or services under Federal awards that were not adequately procured based on the regulations in the Uniform Guidance and the awarding agency could disallow the costs paid for the goods or services. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend that the Organization update its policies and procedures to ensure compliance with CFR 200.320 regarding noncompetitive procurement. In addition, we recommend that documentation be maintained for all procurement decisions in accordance with established policy.