Audit 301868

Federal Agency: U.S. Department of Justice Federal Program Title: Crime Victim Assistance Federal Assistance Listing Number: 16.575 Pass-Through Agency: Minnesota Office of Justice Programs Pass-Through Number(s): A-CVS-2022-AMS-157 Award Period: 10/01/2021 to 09/30/2023 Type of Finding: • Material Weakness in Internal Control over Major Federal Programs, Material Noncompliance, and Other Matters Criteria or Specific Requirement: Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Condition: The Organization does not have a written procurement policy in accordance with Uniform Guidance. In addition, during our testing, we noted the Organization did not apply any procurement procedures for three small purchases as they did not perform appropriate procedures nor retain adequate documentation in accordance with Uniform Guidance. Questioned Costs: $46,557 Context: The Organization should develop a procurement policy that conforms with Uniform Guidance. Three out of the three procurement selections did not have procurement procedures followed. Cause: The Organization was unaware its policy was not in accordance with Uniform Guidance; thus, leading to the lack of procedures performed and documentation retained. Effect: Potential effect of noncompliance with Uniform Guidance when procuring goods and services for expenditures over federal awards. Repeat Finding: This is not a repeat finding. Recommendation: The Organization should review 2 CFR sections 200.318 through 200.326 requirements for procurement. The Organization should also provide training to the various individuals involved in the procurement process to ensure they understand the applicable requirements. Views of Responsible Officials and Planned Corrective Actions: The Organization will review the procurement standards as well as provide the necessary training to understand applicable procurement requirements.

Federal Agency: U.S. Department of Justice Federal Program Title: Crime Victim Assistance Federal Assistance Listing Number: 16.575 Pass-Through Agency: Minnesota Office of Justice Programs Pass-Through Number(s): A-CVS-2022-AMS-157 Award Period: 10/01/2021 to 09/30/2023 Type of Finding: • Significant Deficiency in Internal Control over Major Federal Programs Criteria or Specific Requirement: Under 2 CFR section 200.303, a non-federal entity must establish and maintain effective internal controls over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Timely review and approval should be maintained to ensure accurate amounts are being drawn down and accurate reports are submitted. Condition: The Organization does not have adequate internal controls in place to ensure cash drawdowns and required reports are approved by the appropriate personnel before being submitted. Questioned Costs: N/A Context: Three of the twelve reimbursement requests and five of the nine reports selected for testing did not have support retained to show the drawdowns, financial status reports, and other performance reports were reviewed and approved prior to submission. Cause: Management currently does not have a separate individual assigned to review the cash drawdowns and required reports for the Crime Victim Assistance program after being prepared by the Director of Finance. Effect: Potential for inaccurate amounts of funds to be requested or inaccurate information reported. Repeat Finding: This is not a repeat finding. Recommendation: A separate individual with supervisory authority over the preparer should be assigned to review and approve the cash drawdowns and reports prior to submission. Views of Responsible Officials and Planned Corrective Actions: The Organization will designate an individual to review and approve the cash drawdowns and reports prior to submission.

Federal Agency: U.S. Department of Justice Federal Program Title: Crime Victim Assistance Federal Assistance Listing Number: 16.575 Pass-Through Agency: Minnesota Office of Justice Programs Pass-Through Number(s): A-CVS-2022-AMS-157 Award Period: 10/01/2021 to 09/30/2023 Type of Finding: • Material Weakness in Internal Control over Major Federal Programs, Material Noncompliance, and Other Matters Criteria or Specific Requirement: Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Condition: The Organization does not have a written procurement policy in accordance with Uniform Guidance. In addition, during our testing, we noted the Organization did not apply any procurement procedures for three small purchases as they did not perform appropriate procedures nor retain adequate documentation in accordance with Uniform Guidance. Questioned Costs: $46,557 Context: The Organization should develop a procurement policy that conforms with Uniform Guidance. Three out of the three procurement selections did not have procurement procedures followed. Cause: The Organization was unaware its policy was not in accordance with Uniform Guidance; thus, leading to the lack of procedures performed and documentation retained. Effect: Potential effect of noncompliance with Uniform Guidance when procuring goods and services for expenditures over federal awards. Repeat Finding: This is not a repeat finding. Recommendation: The Organization should review 2 CFR sections 200.318 through 200.326 requirements for procurement. The Organization should also provide training to the various individuals involved in the procurement process to ensure they understand the applicable requirements. Views of Responsible Officials and Planned Corrective Actions: The Organization will review the procurement standards as well as provide the necessary training to understand applicable procurement requirements.

Federal Agency: U.S. Department of Justice Federal Program Title: Crime Victim Assistance Federal Assistance Listing Number: 16.575 Pass-Through Agency: Minnesota Office of Justice Programs Pass-Through Number(s): A-CVS-2022-AMS-157 Award Period: 10/01/2021 to 09/30/2023 Type of Finding: • Significant Deficiency in Internal Control over Major Federal Programs Criteria or Specific Requirement: Under 2 CFR section 200.303, a non-federal entity must establish and maintain effective internal controls over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Timely review and approval should be maintained to ensure accurate amounts are being drawn down and accurate reports are submitted. Condition: The Organization does not have adequate internal controls in place to ensure cash drawdowns and required reports are approved by the appropriate personnel before being submitted. Questioned Costs: N/A Context: Three of the twelve reimbursement requests and five of the nine reports selected for testing did not have support retained to show the drawdowns, financial status reports, and other performance reports were reviewed and approved prior to submission. Cause: Management currently does not have a separate individual assigned to review the cash drawdowns and required reports for the Crime Victim Assistance program after being prepared by the Director of Finance. Effect: Potential for inaccurate amounts of funds to be requested or inaccurate information reported. Repeat Finding: This is not a repeat finding. Recommendation: A separate individual with supervisory authority over the preparer should be assigned to review and approve the cash drawdowns and reports prior to submission. Views of Responsible Officials and Planned Corrective Actions: The Organization will designate an individual to review and approve the cash drawdowns and reports prior to submission.