U.S. Department of Housing and Urban Development
Continuum of Care – Assistance #14.267
#2023-005 – Major Federal Award Finding – Special Tests and Provisions
Nature of Finding: Compliance Finding Special Tests and Provisions and Significant Deficiency in Internal Controls over Compliance
This is a repeat of prior year finding #2022-005.
Criteria/Condition: Per 24 CFR 578.49, rent paid must be reasonable in relation to rents being charged in the area for comparable space. The Organization did not have controls in place to verify that rent paid is reasonable in relation to rents being charged in the area for comparable space.
Cause/Context: Controls were not in place to ensure rent reasonableness. For the rent payments tested, we noted that management's conclusions for rent reasonableness was not documented.
Effect: A lack of controls could result in questioned costs and an inappropriate amount of rent payments being charged to the federal program.
Recommendation: We recommend management establish procedures and controls to require that evidence of review for rent reasonableness be maintained, and that the related conclusions are documented.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
For each client in the HEAL program, where the Organization pays rent for the client, a rent reasonableness form will be completed by the HEAL program staff and approved by the HEAL Program Director and Senior Director. The form will be saved in the client’s file within the Bizstream client management program. The rent reasonableness form will also be submitted to the finance department prior to, or along with, a request for the client’s first rent payment.
U.S. Department of Housing and Urban Development
Continuum of Care – Assistance #14.267
#2023-006 – Major Federal Award Finding - Period of Performance Nature of Finding: Compliance Finding Period of Performance and Material Weakness in Internal Controls over Compliance
Criteria/Condition: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance. The Organization did not have controls in place to verify that costs were being charged to the award in the correct period of performance.
Questioned Costs: $4,035
Identification of How Questioned Costs Were Computed: A sample of 40 non-payroll expenditures totaling approximately $49,000 was selected from a population of approximately $764,000 of non-payroll expenditures. An amount of $263 from an invoice that was selected for testing of non-payroll expenditures charged to the Continuum of Care program was related to the year ending September 30, 2024 and was inappropriately charged to the grant during 2023. Questioned costs are estimated by projecting the error identified in the sample tested to the population of non-payroll expenditures of the Continuum of Care program.
Cause/Context: There are not proper controls in place to review invoices and assign them to the appropriate grant period. One expenditure out of forty non-payroll related expenditures tested for the Continuum of Care grant was for a contracted monthly service that covered multiple performance periods but was billed in its entirety to the current fiscal year.
Effect: An overstatement of expenditures for the Continuum of Care grant was reported in the current year.
Recommendation: We recommend procedures are established to review for proper grant period when recording transactions and creating monthly reimbursement requests.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
1. The Staff Accountant will review the period each expenditure is related to and record the invoice to the appropriate period when entering it into accounts payable. The month and year will be noted on the invoice.
2. The CFO will review the month and year noted by the Staff Accountant prior to entry into accounts payable.
U.S. Department of Housing and Urban Development
Continuum of Care – Assistance #14.267 #2023-007 – Major Federal Award Finding
Nature of Finding: Significant Deficiency in Internal Controls over Compliance
Criteria/Condition: The U.S. Department of Housing and Urban Development (HUD) conducted a monitoring assessment of the Continuum of Care Program during the year ended September 30, 2023 in order to assess the Organization’s performance and compliance with applicable federal program requirements. There were various findings noted within the monitoring report. The Organization has addressed most of the findings, but some of the findings remain open.
Cause/Context: The Organization’s responses to the findings included within the HUD monitoring report were not provided in a timely manner, and various findings were not closed timely.
Effect: Continued delay in response to findings could result in disciplinary action from HUD, including reduction or elimination of financial assistance.
Recommendation: We recommend that all open items from the 2023 HUD monitoring report be closed by the Organization. We also recommend that the Organization respond timely to HUD to clear any findings resulting from the upcoming monitoring assessment.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will address any open items from the 2023 HUD monitoring assessment and close any findings. Future findings, if any, will be closed with HUD within 30 days of receipt of the findings.
U.S. Department of Housing and Urban Development
Continuum of Care – Assistance #14.267
#2023-005 – Major Federal Award Finding – Special Tests and Provisions
Nature of Finding: Compliance Finding Special Tests and Provisions and Significant Deficiency in Internal Controls over Compliance
This is a repeat of prior year finding #2022-005.
Criteria/Condition: Per 24 CFR 578.49, rent paid must be reasonable in relation to rents being charged in the area for comparable space. The Organization did not have controls in place to verify that rent paid is reasonable in relation to rents being charged in the area for comparable space.
Cause/Context: Controls were not in place to ensure rent reasonableness. For the rent payments tested, we noted that management's conclusions for rent reasonableness was not documented.
Effect: A lack of controls could result in questioned costs and an inappropriate amount of rent payments being charged to the federal program.
Recommendation: We recommend management establish procedures and controls to require that evidence of review for rent reasonableness be maintained, and that the related conclusions are documented.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
For each client in the HEAL program, where the Organization pays rent for the client, a rent reasonableness form will be completed by the HEAL program staff and approved by the HEAL Program Director and Senior Director. The form will be saved in the client’s file within the Bizstream client management program. The rent reasonableness form will also be submitted to the finance department prior to, or along with, a request for the client’s first rent payment.
U.S. Department of Housing and Urban Development
Continuum of Care – Assistance #14.267
#2023-006 – Major Federal Award Finding - Period of Performance Nature of Finding: Compliance Finding Period of Performance and Material Weakness in Internal Controls over Compliance
Criteria/Condition: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance. The Organization did not have controls in place to verify that costs were being charged to the award in the correct period of performance.
Questioned Costs: $4,035
Identification of How Questioned Costs Were Computed: A sample of 40 non-payroll expenditures totaling approximately $49,000 was selected from a population of approximately $764,000 of non-payroll expenditures. An amount of $263 from an invoice that was selected for testing of non-payroll expenditures charged to the Continuum of Care program was related to the year ending September 30, 2024 and was inappropriately charged to the grant during 2023. Questioned costs are estimated by projecting the error identified in the sample tested to the population of non-payroll expenditures of the Continuum of Care program.
Cause/Context: There are not proper controls in place to review invoices and assign them to the appropriate grant period. One expenditure out of forty non-payroll related expenditures tested for the Continuum of Care grant was for a contracted monthly service that covered multiple performance periods but was billed in its entirety to the current fiscal year.
Effect: An overstatement of expenditures for the Continuum of Care grant was reported in the current year.
Recommendation: We recommend procedures are established to review for proper grant period when recording transactions and creating monthly reimbursement requests.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
1. The Staff Accountant will review the period each expenditure is related to and record the invoice to the appropriate period when entering it into accounts payable. The month and year will be noted on the invoice.
2. The CFO will review the month and year noted by the Staff Accountant prior to entry into accounts payable.
U.S. Department of Housing and Urban Development
Continuum of Care – Assistance #14.267 #2023-007 – Major Federal Award Finding
Nature of Finding: Significant Deficiency in Internal Controls over Compliance
Criteria/Condition: The U.S. Department of Housing and Urban Development (HUD) conducted a monitoring assessment of the Continuum of Care Program during the year ended September 30, 2023 in order to assess the Organization’s performance and compliance with applicable federal program requirements. There were various findings noted within the monitoring report. The Organization has addressed most of the findings, but some of the findings remain open.
Cause/Context: The Organization’s responses to the findings included within the HUD monitoring report were not provided in a timely manner, and various findings were not closed timely.
Effect: Continued delay in response to findings could result in disciplinary action from HUD, including reduction or elimination of financial assistance.
Recommendation: We recommend that all open items from the 2023 HUD monitoring report be closed by the Organization. We also recommend that the Organization respond timely to HUD to clear any findings resulting from the upcoming monitoring assessment.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will address any open items from the 2023 HUD monitoring assessment and close any findings. Future findings, if any, will be closed with HUD within 30 days of receipt of the findings.
U.S. Department of Housing and Urban Development
Continuum of Care – Assistance #14.267
#2023-005 – Major Federal Award Finding – Special Tests and Provisions
Nature of Finding: Compliance Finding Special Tests and Provisions and Significant Deficiency in Internal Controls over Compliance
This is a repeat of prior year finding #2022-005.
Criteria/Condition: Per 24 CFR 578.49, rent paid must be reasonable in relation to rents being charged in the area for comparable space. The Organization did not have controls in place to verify that rent paid is reasonable in relation to rents being charged in the area for comparable space.
Cause/Context: Controls were not in place to ensure rent reasonableness. For the rent payments tested, we noted that management's conclusions for rent reasonableness was not documented.
Effect: A lack of controls could result in questioned costs and an inappropriate amount of rent payments being charged to the federal program.
Recommendation: We recommend management establish procedures and controls to require that evidence of review for rent reasonableness be maintained, and that the related conclusions are documented.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
For each client in the HEAL program, where the Organization pays rent for the client, a rent reasonableness form will be completed by the HEAL program staff and approved by the HEAL Program Director and Senior Director. The form will be saved in the client’s file within the Bizstream client management program. The rent reasonableness form will also be submitted to the finance department prior to, or along with, a request for the client’s first rent payment.
U.S. Department of Housing and Urban Development
Continuum of Care – Assistance #14.267
#2023-006 – Major Federal Award Finding - Period of Performance Nature of Finding: Compliance Finding Period of Performance and Material Weakness in Internal Controls over Compliance
Criteria/Condition: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance. The Organization did not have controls in place to verify that costs were being charged to the award in the correct period of performance.
Questioned Costs: $4,035
Identification of How Questioned Costs Were Computed: A sample of 40 non-payroll expenditures totaling approximately $49,000 was selected from a population of approximately $764,000 of non-payroll expenditures. An amount of $263 from an invoice that was selected for testing of non-payroll expenditures charged to the Continuum of Care program was related to the year ending September 30, 2024 and was inappropriately charged to the grant during 2023. Questioned costs are estimated by projecting the error identified in the sample tested to the population of non-payroll expenditures of the Continuum of Care program.
Cause/Context: There are not proper controls in place to review invoices and assign them to the appropriate grant period. One expenditure out of forty non-payroll related expenditures tested for the Continuum of Care grant was for a contracted monthly service that covered multiple performance periods but was billed in its entirety to the current fiscal year.
Effect: An overstatement of expenditures for the Continuum of Care grant was reported in the current year.
Recommendation: We recommend procedures are established to review for proper grant period when recording transactions and creating monthly reimbursement requests.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
1. The Staff Accountant will review the period each expenditure is related to and record the invoice to the appropriate period when entering it into accounts payable. The month and year will be noted on the invoice.
2. The CFO will review the month and year noted by the Staff Accountant prior to entry into accounts payable.
U.S. Department of Housing and Urban Development
Continuum of Care – Assistance #14.267 #2023-007 – Major Federal Award Finding
Nature of Finding: Significant Deficiency in Internal Controls over Compliance
Criteria/Condition: The U.S. Department of Housing and Urban Development (HUD) conducted a monitoring assessment of the Continuum of Care Program during the year ended September 30, 2023 in order to assess the Organization’s performance and compliance with applicable federal program requirements. There were various findings noted within the monitoring report. The Organization has addressed most of the findings, but some of the findings remain open.
Cause/Context: The Organization’s responses to the findings included within the HUD monitoring report were not provided in a timely manner, and various findings were not closed timely.
Effect: Continued delay in response to findings could result in disciplinary action from HUD, including reduction or elimination of financial assistance.
Recommendation: We recommend that all open items from the 2023 HUD monitoring report be closed by the Organization. We also recommend that the Organization respond timely to HUD to clear any findings resulting from the upcoming monitoring assessment.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will address any open items from the 2023 HUD monitoring assessment and close any findings. Future findings, if any, will be closed with HUD within 30 days of receipt of the findings.
U.S. Department of Housing and Urban Development
Continuum of Care – Assistance #14.267
#2023-005 – Major Federal Award Finding – Special Tests and Provisions
Nature of Finding: Compliance Finding Special Tests and Provisions and Significant Deficiency in Internal Controls over Compliance
This is a repeat of prior year finding #2022-005.
Criteria/Condition: Per 24 CFR 578.49, rent paid must be reasonable in relation to rents being charged in the area for comparable space. The Organization did not have controls in place to verify that rent paid is reasonable in relation to rents being charged in the area for comparable space.
Cause/Context: Controls were not in place to ensure rent reasonableness. For the rent payments tested, we noted that management's conclusions for rent reasonableness was not documented.
Effect: A lack of controls could result in questioned costs and an inappropriate amount of rent payments being charged to the federal program.
Recommendation: We recommend management establish procedures and controls to require that evidence of review for rent reasonableness be maintained, and that the related conclusions are documented.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
For each client in the HEAL program, where the Organization pays rent for the client, a rent reasonableness form will be completed by the HEAL program staff and approved by the HEAL Program Director and Senior Director. The form will be saved in the client’s file within the Bizstream client management program. The rent reasonableness form will also be submitted to the finance department prior to, or along with, a request for the client’s first rent payment.
U.S. Department of Housing and Urban Development
Continuum of Care – Assistance #14.267
#2023-006 – Major Federal Award Finding - Period of Performance Nature of Finding: Compliance Finding Period of Performance and Material Weakness in Internal Controls over Compliance
Criteria/Condition: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance. The Organization did not have controls in place to verify that costs were being charged to the award in the correct period of performance.
Questioned Costs: $4,035
Identification of How Questioned Costs Were Computed: A sample of 40 non-payroll expenditures totaling approximately $49,000 was selected from a population of approximately $764,000 of non-payroll expenditures. An amount of $263 from an invoice that was selected for testing of non-payroll expenditures charged to the Continuum of Care program was related to the year ending September 30, 2024 and was inappropriately charged to the grant during 2023. Questioned costs are estimated by projecting the error identified in the sample tested to the population of non-payroll expenditures of the Continuum of Care program.
Cause/Context: There are not proper controls in place to review invoices and assign them to the appropriate grant period. One expenditure out of forty non-payroll related expenditures tested for the Continuum of Care grant was for a contracted monthly service that covered multiple performance periods but was billed in its entirety to the current fiscal year.
Effect: An overstatement of expenditures for the Continuum of Care grant was reported in the current year.
Recommendation: We recommend procedures are established to review for proper grant period when recording transactions and creating monthly reimbursement requests.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
1. The Staff Accountant will review the period each expenditure is related to and record the invoice to the appropriate period when entering it into accounts payable. The month and year will be noted on the invoice.
2. The CFO will review the month and year noted by the Staff Accountant prior to entry into accounts payable.
U.S. Department of Housing and Urban Development
Continuum of Care – Assistance #14.267 #2023-007 – Major Federal Award Finding
Nature of Finding: Significant Deficiency in Internal Controls over Compliance
Criteria/Condition: The U.S. Department of Housing and Urban Development (HUD) conducted a monitoring assessment of the Continuum of Care Program during the year ended September 30, 2023 in order to assess the Organization’s performance and compliance with applicable federal program requirements. There were various findings noted within the monitoring report. The Organization has addressed most of the findings, but some of the findings remain open.
Cause/Context: The Organization’s responses to the findings included within the HUD monitoring report were not provided in a timely manner, and various findings were not closed timely.
Effect: Continued delay in response to findings could result in disciplinary action from HUD, including reduction or elimination of financial assistance.
Recommendation: We recommend that all open items from the 2023 HUD monitoring report be closed by the Organization. We also recommend that the Organization respond timely to HUD to clear any findings resulting from the upcoming monitoring assessment.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will address any open items from the 2023 HUD monitoring assessment and close any findings. Future findings, if any, will be closed with HUD within 30 days of receipt of the findings.
U.S. Department of Homeland Security, U.S. Department of Justice, and U.S. Department of Health and Human Services
#2023-011 – Major Federal Award Finding
Nature of Finding: Significant Deficiency in Internal Controls over Compliance
This is a repeat of prior year finding #2022-007.
Criteria/Condition: Per 2 CFR 200.510(b), the auditee must prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee's financial statements, which must include the total federal awards expended, as determined in accordance with §200.502. For SEFA reporting, federal expenditures were not disclosed for one program and were overstated or understated for other programs.
Cause/Context: Expenditures for the Emergency Food and Shelter National Board Program were excluded from the client-prepared SEFA. There were various other grants with allocations between state and federal funding that were not presented properly on the SEFA. The SEFA presented has been adjusted for these errors.
Effect: Controls in place did not sufficiently ensure the completeness and accuracy of the SEFA.
Recommendation: We recommend the Organization enhance its procedures and controls to ensure data accumulated to prepare the SEFA is complete and accurate.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
The Schedule of Expenditures of Federal Awards (SEFA) will be reviewed for accuracy by either the CFO or CEO after it is produced, to ensure that all federal awards are included, and that the amounts on the schedule are accurate.
U.S. Department of Homeland Security, U.S. Department of Justice, and U.S. Department of Health and Human Services
#2023-011 – Major Federal Award Finding
Nature of Finding: Significant Deficiency in Internal Controls over Compliance
This is a repeat of prior year finding #2022-007.
Criteria/Condition: Per 2 CFR 200.510(b), the auditee must prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee's financial statements, which must include the total federal awards expended, as determined in accordance with §200.502. For SEFA reporting, federal expenditures were not disclosed for one program and were overstated or understated for other programs.
Cause/Context: Expenditures for the Emergency Food and Shelter National Board Program were excluded from the client-prepared SEFA. There were various other grants with allocations between state and federal funding that were not presented properly on the SEFA. The SEFA presented has been adjusted for these errors.
Effect: Controls in place did not sufficiently ensure the completeness and accuracy of the SEFA.
Recommendation: We recommend the Organization enhance its procedures and controls to ensure data accumulated to prepare the SEFA is complete and accurate.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
The Schedule of Expenditures of Federal Awards (SEFA) will be reviewed for accuracy by either the CFO or CEO after it is produced, to ensure that all federal awards are included, and that the amounts on the schedule are accurate.
U.S. Department of Homeland Security, U.S. Department of Justice, and U.S. Department of Health and Human Services
#2023-011 – Major Federal Award Finding
Nature of Finding: Significant Deficiency in Internal Controls over Compliance
This is a repeat of prior year finding #2022-007.
Criteria/Condition: Per 2 CFR 200.510(b), the auditee must prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee's financial statements, which must include the total federal awards expended, as determined in accordance with §200.502. For SEFA reporting, federal expenditures were not disclosed for one program and were overstated or understated for other programs.
Cause/Context: Expenditures for the Emergency Food and Shelter National Board Program were excluded from the client-prepared SEFA. There were various other grants with allocations between state and federal funding that were not presented properly on the SEFA. The SEFA presented has been adjusted for these errors.
Effect: Controls in place did not sufficiently ensure the completeness and accuracy of the SEFA.
Recommendation: We recommend the Organization enhance its procedures and controls to ensure data accumulated to prepare the SEFA is complete and accurate.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
The Schedule of Expenditures of Federal Awards (SEFA) will be reviewed for accuracy by either the CFO or CEO after it is produced, to ensure that all federal awards are included, and that the amounts on the schedule are accurate.
U.S. Department of Justice
Crime Victim Assistance – Assistance #16.575
#2023-008 – Major Federal Award Finding – Reporting
Nature of Finding: Compliance Finding Reporting and Material Weakness in Internal Controls over Compliance
This is a repeat of prior year finding #2022-006.
Criteria/Condition: Federal regulations 2 CFR 200.328 - 200.329 provide that required reporting under the federal program must be completed timely and accurately. The federal award agreement includes specific report filing due dates. Segregation of duties is also a key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction or process from beginning to end. We noted during testing of sixteen different required reports that five of these reports tested were not filed in a timely manner. There were also no review procedures in place surrounding these reports.
Cause/Context: Controls were not in place to ensure timely reporting. Only one individual was involved in the reporting process for the reports. A total of five of the reports tested were submitted more than ten days late.
Effect: A lack of controls could result in late or failed reporting.
Recommendation: We recommend the Organization establish procedures and controls to ensure financial and performance reports are filed timely.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will ensure that all federal award reports are filed in a timely manner. The Organization is in the process of posting a new position, Director of Grants and Compliance. The individual in this new role will be responsible for tracking report due dates and working with the individuals responsible for the content of these reports to ensure the information is accurate and on time. In situations where the Director of Grants and Compliance is responsible for gathering the data for required reporting, the data will be reviewed by either the CFO or CEO prior to submission of the report.
U.S. Department of Justice
Crime Victim Assistance – Assistance #16.575
#2023-009 – Major Federal Award Finding – Cash Management
Nature of Finding: Compliance Finding Cash Management and Significant Deficiency in Internal Controls over Compliance
Criteria/Condition: 2 CFR 200.305 requires that non-federal entities must minimize the time elapsing between the transfer of federal funds to the non-federal entity and the subsequent disbursement of the funds by the non-federal entity for program costs. The Organization did not have proper controls in place to verify that specific vendor invoices were paid within a reasonable amount of time of requesting reimbursement for the expenditures.
Questioned Costs: $2,381
Identification of How Questioned Costs Were Computed: The issues of noncompliance related to cash management was limited to one vendor that was not paid within a reasonable amount of time of being reimbursed for the costs. This was determined to be an isolated incident. Questioned costs include the two invoices that were charged to the grant for this vendor during the year ended September 30, 2023 and were not paid to the vendor within a reasonable amount of time of being reimbursed for the expenditures.
Cause/Context: Controls were not in place to ensure expenditures were paid to the vendor prior to requesting reimbursements. This circumstance was determined to be an isolated incident due to the unique nature of the vendor invoices. The Organization was withholding payment to the vendor until it determined that both invoices were proper.
Effect: The lack of controls could result in requests for reimbursement being submitted for unpaid expenditures.
Recommendation: We recommend the Organization establish procedures and incorporate controls to review that expenditures are paid prior to submitting requests for reimbursement.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
Each month, an aged open accounts payable report will be produced as part of the month end closing. Invoices that are past due will be paid in the following batch of payments (which are typically run weekly). If it is determined that the invoice is not being paid for a valid reason, it will be removed from accounts payable at that time.
U.S. Department of Justice
Crime Victim Assistance – Assistance #16.575
#2023-009 – Major Federal Award Finding – Cash Management
Nature of Finding: Compliance Finding Cash Management and Significant Deficiency in Internal Controls over Compliance
Criteria/Condition: 2 CFR 200.305 requires that non-federal entities must minimize the time elapsing between the transfer of federal funds to the non-federal entity and the subsequent disbursement of the funds by the non-federal entity for program costs. The Organization did not have proper controls in place to verify that specific vendor invoices were paid within a reasonable amount of time of requesting reimbursement for the expenditures.
Questioned Costs: $2,381
Identification of How Questioned Costs Were Computed: The issues of noncompliance related to cash management was limited to one vendor that was not paid within a reasonable amount of time of being reimbursed for the costs. This was determined to be an isolated incident. Questioned costs include the two invoices that were charged to the grant for this vendor during the year ended September 30, 2023 and were not paid to the vendor within a reasonable amount of time of being reimbursed for the expenditures.
Cause/Context: Controls were not in place to ensure expenditures were paid to the vendor prior to requesting reimbursements. This circumstance was determined to be an isolated incident due to the unique nature of the vendor invoices. The Organization was withholding payment to the vendor until it determined that both invoices were proper.
Effect: The lack of controls could result in requests for reimbursement being submitted for unpaid expenditures.
Recommendation: We recommend the Organization establish procedures and incorporate controls to review that expenditures are paid prior to submitting requests for reimbursement.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
Each month, an aged open accounts payable report will be produced as part of the month end closing. Invoices that are past due will be paid in the following batch of payments (which are typically run weekly). If it is determined that the invoice is not being paid for a valid reason, it will be removed from accounts payable at that time.
#2023-010 – Major Federal Award Finding – Period of Performance
Nature of Finding: Compliance Finding Period of Performance and Material Weakness in Internal Controls over Compliance
Criteria/Condition: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance. The Organization did not have controls in place to verify that costs were being charged to the award in the correct period of performance.
Questioned Costs: $20,790
Identification of How Questioned Costs Were Computed: A sample of 40 non-payroll expenditures totaling approximately $48,000 was selected from a population of approximately $552,000 of non-payroll expenditures. An amount of $1,817 combined from two invoices that were charged to the Crime Victim Assistance program was related to the year ending September 30, 2024 and was inappropriately charged to the grant during 2023. Questioned costs are estimated by projecting the error identified in the sample tested to the population of non-payroll expenditures of the Crime Victim Assistance program.
Cause/Context: There are not proper controls in place to review invoices and assign them to the appropriate grant period. Two expenditures out of forty non-payroll related expenditures tested for the Crime Victim Assistance grant was for a contracted annual service that covered multiple performance periods but was billed in its entirety to the current fiscal year.
Effect: An overstatement of expenditures for the Crime Victim Assistance grant was reported in the current year.
Recommendation: We recommend procedures are established to review for proper grant period when recording transactions and creating monthly reimbursement requests.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures.
1. The Staff Accountant will review the period each expenditure is related to and record the invoice to the appropriate period when entering it into accounts payable. The month and year will be noted on the invoice.
2. The CFO will review the month and year noted by the Staff Accountant prior to entry into accounts payable.
U.S. Department of Homeland Security, U.S. Department of Justice, and U.S. Department of Health and Human Services
#2023-011 – Major Federal Award Finding
Nature of Finding: Significant Deficiency in Internal Controls over Compliance
This is a repeat of prior year finding #2022-007.
Criteria/Condition: Per 2 CFR 200.510(b), the auditee must prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee's financial statements, which must include the total federal awards expended, as determined in accordance with §200.502. For SEFA reporting, federal expenditures were not disclosed for one program and were overstated or understated for other programs.
Cause/Context: Expenditures for the Emergency Food and Shelter National Board Program were excluded from the client-prepared SEFA. There were various other grants with allocations between state and federal funding that were not presented properly on the SEFA. The SEFA presented has been adjusted for these errors.
Effect: Controls in place did not sufficiently ensure the completeness and accuracy of the SEFA.
Recommendation: We recommend the Organization enhance its procedures and controls to ensure data accumulated to prepare the SEFA is complete and accurate.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
The Schedule of Expenditures of Federal Awards (SEFA) will be reviewed for accuracy by either the CFO or CEO after it is produced, to ensure that all federal awards are included, and that the amounts on the schedule are accurate.
U.S. Department of Justice
Crime Victim Assistance – Assistance #16.575
#2023-008 – Major Federal Award Finding – Reporting
Nature of Finding: Compliance Finding Reporting and Material Weakness in Internal Controls over Compliance
This is a repeat of prior year finding #2022-006.
Criteria/Condition: Federal regulations 2 CFR 200.328 - 200.329 provide that required reporting under the federal program must be completed timely and accurately. The federal award agreement includes specific report filing due dates. Segregation of duties is also a key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction or process from beginning to end. We noted during testing of sixteen different required reports that five of these reports tested were not filed in a timely manner. There were also no review procedures in place surrounding these reports.
Cause/Context: Controls were not in place to ensure timely reporting. Only one individual was involved in the reporting process for the reports. A total of five of the reports tested were submitted more than ten days late.
Effect: A lack of controls could result in late or failed reporting.
Recommendation: We recommend the Organization establish procedures and controls to ensure financial and performance reports are filed timely.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will ensure that all federal award reports are filed in a timely manner. The Organization is in the process of posting a new position, Director of Grants and Compliance. The individual in this new role will be responsible for tracking report due dates and working with the individuals responsible for the content of these reports to ensure the information is accurate and on time. In situations where the Director of Grants and Compliance is responsible for gathering the data for required reporting, the data will be reviewed by either the CFO or CEO prior to submission of the report.
U.S. Department of Justice
Crime Victim Assistance – Assistance #16.575
#2023-009 – Major Federal Award Finding – Cash Management
Nature of Finding: Compliance Finding Cash Management and Significant Deficiency in Internal Controls over Compliance
Criteria/Condition: 2 CFR 200.305 requires that non-federal entities must minimize the time elapsing between the transfer of federal funds to the non-federal entity and the subsequent disbursement of the funds by the non-federal entity for program costs. The Organization did not have proper controls in place to verify that specific vendor invoices were paid within a reasonable amount of time of requesting reimbursement for the expenditures.
Questioned Costs: $2,381
Identification of How Questioned Costs Were Computed: The issues of noncompliance related to cash management was limited to one vendor that was not paid within a reasonable amount of time of being reimbursed for the costs. This was determined to be an isolated incident. Questioned costs include the two invoices that were charged to the grant for this vendor during the year ended September 30, 2023 and were not paid to the vendor within a reasonable amount of time of being reimbursed for the expenditures.
Cause/Context: Controls were not in place to ensure expenditures were paid to the vendor prior to requesting reimbursements. This circumstance was determined to be an isolated incident due to the unique nature of the vendor invoices. The Organization was withholding payment to the vendor until it determined that both invoices were proper.
Effect: The lack of controls could result in requests for reimbursement being submitted for unpaid expenditures.
Recommendation: We recommend the Organization establish procedures and incorporate controls to review that expenditures are paid prior to submitting requests for reimbursement.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
Each month, an aged open accounts payable report will be produced as part of the month end closing. Invoices that are past due will be paid in the following batch of payments (which are typically run weekly). If it is determined that the invoice is not being paid for a valid reason, it will be removed from accounts payable at that time.
U.S. Department of Justice
Crime Victim Assistance – Assistance #16.575
#2023-009 – Major Federal Award Finding – Cash Management
Nature of Finding: Compliance Finding Cash Management and Significant Deficiency in Internal Controls over Compliance
Criteria/Condition: 2 CFR 200.305 requires that non-federal entities must minimize the time elapsing between the transfer of federal funds to the non-federal entity and the subsequent disbursement of the funds by the non-federal entity for program costs. The Organization did not have proper controls in place to verify that specific vendor invoices were paid within a reasonable amount of time of requesting reimbursement for the expenditures.
Questioned Costs: $2,381
Identification of How Questioned Costs Were Computed: The issues of noncompliance related to cash management was limited to one vendor that was not paid within a reasonable amount of time of being reimbursed for the costs. This was determined to be an isolated incident. Questioned costs include the two invoices that were charged to the grant for this vendor during the year ended September 30, 2023 and were not paid to the vendor within a reasonable amount of time of being reimbursed for the expenditures.
Cause/Context: Controls were not in place to ensure expenditures were paid to the vendor prior to requesting reimbursements. This circumstance was determined to be an isolated incident due to the unique nature of the vendor invoices. The Organization was withholding payment to the vendor until it determined that both invoices were proper.
Effect: The lack of controls could result in requests for reimbursement being submitted for unpaid expenditures.
Recommendation: We recommend the Organization establish procedures and incorporate controls to review that expenditures are paid prior to submitting requests for reimbursement.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
Each month, an aged open accounts payable report will be produced as part of the month end closing. Invoices that are past due will be paid in the following batch of payments (which are typically run weekly). If it is determined that the invoice is not being paid for a valid reason, it will be removed from accounts payable at that time.
#2023-010 – Major Federal Award Finding – Period of Performance
Nature of Finding: Compliance Finding Period of Performance and Material Weakness in Internal Controls over Compliance
Criteria/Condition: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance. The Organization did not have controls in place to verify that costs were being charged to the award in the correct period of performance.
Questioned Costs: $20,790
Identification of How Questioned Costs Were Computed: A sample of 40 non-payroll expenditures totaling approximately $48,000 was selected from a population of approximately $552,000 of non-payroll expenditures. An amount of $1,817 combined from two invoices that were charged to the Crime Victim Assistance program was related to the year ending September 30, 2024 and was inappropriately charged to the grant during 2023. Questioned costs are estimated by projecting the error identified in the sample tested to the population of non-payroll expenditures of the Crime Victim Assistance program.
Cause/Context: There are not proper controls in place to review invoices and assign them to the appropriate grant period. Two expenditures out of forty non-payroll related expenditures tested for the Crime Victim Assistance grant was for a contracted annual service that covered multiple performance periods but was billed in its entirety to the current fiscal year.
Effect: An overstatement of expenditures for the Crime Victim Assistance grant was reported in the current year.
Recommendation: We recommend procedures are established to review for proper grant period when recording transactions and creating monthly reimbursement requests.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures.
1. The Staff Accountant will review the period each expenditure is related to and record the invoice to the appropriate period when entering it into accounts payable. The month and year will be noted on the invoice.
2. The CFO will review the month and year noted by the Staff Accountant prior to entry into accounts payable.
U.S. Department of Homeland Security, U.S. Department of Justice, and U.S. Department of Health and Human Services
#2023-011 – Major Federal Award Finding
Nature of Finding: Significant Deficiency in Internal Controls over Compliance
This is a repeat of prior year finding #2022-007.
Criteria/Condition: Per 2 CFR 200.510(b), the auditee must prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee's financial statements, which must include the total federal awards expended, as determined in accordance with §200.502. For SEFA reporting, federal expenditures were not disclosed for one program and were overstated or understated for other programs.
Cause/Context: Expenditures for the Emergency Food and Shelter National Board Program were excluded from the client-prepared SEFA. There were various other grants with allocations between state and federal funding that were not presented properly on the SEFA. The SEFA presented has been adjusted for these errors.
Effect: Controls in place did not sufficiently ensure the completeness and accuracy of the SEFA.
Recommendation: We recommend the Organization enhance its procedures and controls to ensure data accumulated to prepare the SEFA is complete and accurate.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
The Schedule of Expenditures of Federal Awards (SEFA) will be reviewed for accuracy by either the CFO or CEO after it is produced, to ensure that all federal awards are included, and that the amounts on the schedule are accurate.
U.S. Department of Justice
Crime Victim Assistance – Assistance #16.575
#2023-008 – Major Federal Award Finding – Reporting
Nature of Finding: Compliance Finding Reporting and Material Weakness in Internal Controls over Compliance
This is a repeat of prior year finding #2022-006.
Criteria/Condition: Federal regulations 2 CFR 200.328 - 200.329 provide that required reporting under the federal program must be completed timely and accurately. The federal award agreement includes specific report filing due dates. Segregation of duties is also a key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction or process from beginning to end. We noted during testing of sixteen different required reports that five of these reports tested were not filed in a timely manner. There were also no review procedures in place surrounding these reports.
Cause/Context: Controls were not in place to ensure timely reporting. Only one individual was involved in the reporting process for the reports. A total of five of the reports tested were submitted more than ten days late.
Effect: A lack of controls could result in late or failed reporting.
Recommendation: We recommend the Organization establish procedures and controls to ensure financial and performance reports are filed timely.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will ensure that all federal award reports are filed in a timely manner. The Organization is in the process of posting a new position, Director of Grants and Compliance. The individual in this new role will be responsible for tracking report due dates and working with the individuals responsible for the content of these reports to ensure the information is accurate and on time. In situations where the Director of Grants and Compliance is responsible for gathering the data for required reporting, the data will be reviewed by either the CFO or CEO prior to submission of the report.
U.S. Department of Justice
Crime Victim Assistance – Assistance #16.575
#2023-009 – Major Federal Award Finding – Cash Management
Nature of Finding: Compliance Finding Cash Management and Significant Deficiency in Internal Controls over Compliance
Criteria/Condition: 2 CFR 200.305 requires that non-federal entities must minimize the time elapsing between the transfer of federal funds to the non-federal entity and the subsequent disbursement of the funds by the non-federal entity for program costs. The Organization did not have proper controls in place to verify that specific vendor invoices were paid within a reasonable amount of time of requesting reimbursement for the expenditures.
Questioned Costs: $2,381
Identification of How Questioned Costs Were Computed: The issues of noncompliance related to cash management was limited to one vendor that was not paid within a reasonable amount of time of being reimbursed for the costs. This was determined to be an isolated incident. Questioned costs include the two invoices that were charged to the grant for this vendor during the year ended September 30, 2023 and were not paid to the vendor within a reasonable amount of time of being reimbursed for the expenditures.
Cause/Context: Controls were not in place to ensure expenditures were paid to the vendor prior to requesting reimbursements. This circumstance was determined to be an isolated incident due to the unique nature of the vendor invoices. The Organization was withholding payment to the vendor until it determined that both invoices were proper.
Effect: The lack of controls could result in requests for reimbursement being submitted for unpaid expenditures.
Recommendation: We recommend the Organization establish procedures and incorporate controls to review that expenditures are paid prior to submitting requests for reimbursement.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
Each month, an aged open accounts payable report will be produced as part of the month end closing. Invoices that are past due will be paid in the following batch of payments (which are typically run weekly). If it is determined that the invoice is not being paid for a valid reason, it will be removed from accounts payable at that time.
U.S. Department of Justice
Crime Victim Assistance – Assistance #16.575
#2023-009 – Major Federal Award Finding – Cash Management
Nature of Finding: Compliance Finding Cash Management and Significant Deficiency in Internal Controls over Compliance
Criteria/Condition: 2 CFR 200.305 requires that non-federal entities must minimize the time elapsing between the transfer of federal funds to the non-federal entity and the subsequent disbursement of the funds by the non-federal entity for program costs. The Organization did not have proper controls in place to verify that specific vendor invoices were paid within a reasonable amount of time of requesting reimbursement for the expenditures.
Questioned Costs: $2,381
Identification of How Questioned Costs Were Computed: The issues of noncompliance related to cash management was limited to one vendor that was not paid within a reasonable amount of time of being reimbursed for the costs. This was determined to be an isolated incident. Questioned costs include the two invoices that were charged to the grant for this vendor during the year ended September 30, 2023 and were not paid to the vendor within a reasonable amount of time of being reimbursed for the expenditures.
Cause/Context: Controls were not in place to ensure expenditures were paid to the vendor prior to requesting reimbursements. This circumstance was determined to be an isolated incident due to the unique nature of the vendor invoices. The Organization was withholding payment to the vendor until it determined that both invoices were proper.
Effect: The lack of controls could result in requests for reimbursement being submitted for unpaid expenditures.
Recommendation: We recommend the Organization establish procedures and incorporate controls to review that expenditures are paid prior to submitting requests for reimbursement.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
Each month, an aged open accounts payable report will be produced as part of the month end closing. Invoices that are past due will be paid in the following batch of payments (which are typically run weekly). If it is determined that the invoice is not being paid for a valid reason, it will be removed from accounts payable at that time.
#2023-010 – Major Federal Award Finding – Period of Performance
Nature of Finding: Compliance Finding Period of Performance and Material Weakness in Internal Controls over Compliance
Criteria/Condition: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance. The Organization did not have controls in place to verify that costs were being charged to the award in the correct period of performance.
Questioned Costs: $20,790
Identification of How Questioned Costs Were Computed: A sample of 40 non-payroll expenditures totaling approximately $48,000 was selected from a population of approximately $552,000 of non-payroll expenditures. An amount of $1,817 combined from two invoices that were charged to the Crime Victim Assistance program was related to the year ending September 30, 2024 and was inappropriately charged to the grant during 2023. Questioned costs are estimated by projecting the error identified in the sample tested to the population of non-payroll expenditures of the Crime Victim Assistance program.
Cause/Context: There are not proper controls in place to review invoices and assign them to the appropriate grant period. Two expenditures out of forty non-payroll related expenditures tested for the Crime Victim Assistance grant was for a contracted annual service that covered multiple performance periods but was billed in its entirety to the current fiscal year.
Effect: An overstatement of expenditures for the Crime Victim Assistance grant was reported in the current year.
Recommendation: We recommend procedures are established to review for proper grant period when recording transactions and creating monthly reimbursement requests.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures.
1. The Staff Accountant will review the period each expenditure is related to and record the invoice to the appropriate period when entering it into accounts payable. The month and year will be noted on the invoice.
2. The CFO will review the month and year noted by the Staff Accountant prior to entry into accounts payable.
U.S. Department of Homeland Security, U.S. Department of Justice, and U.S. Department of Health and Human Services
#2023-011 – Major Federal Award Finding
Nature of Finding: Significant Deficiency in Internal Controls over Compliance
This is a repeat of prior year finding #2022-007.
Criteria/Condition: Per 2 CFR 200.510(b), the auditee must prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee's financial statements, which must include the total federal awards expended, as determined in accordance with §200.502. For SEFA reporting, federal expenditures were not disclosed for one program and were overstated or understated for other programs.
Cause/Context: Expenditures for the Emergency Food and Shelter National Board Program were excluded from the client-prepared SEFA. There were various other grants with allocations between state and federal funding that were not presented properly on the SEFA. The SEFA presented has been adjusted for these errors.
Effect: Controls in place did not sufficiently ensure the completeness and accuracy of the SEFA.
Recommendation: We recommend the Organization enhance its procedures and controls to ensure data accumulated to prepare the SEFA is complete and accurate.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
The Schedule of Expenditures of Federal Awards (SEFA) will be reviewed for accuracy by either the CFO or CEO after it is produced, to ensure that all federal awards are included, and that the amounts on the schedule are accurate.
U.S. Department of Justice
Crime Victim Assistance – Assistance #16.575
#2023-008 – Major Federal Award Finding – Reporting
Nature of Finding: Compliance Finding Reporting and Material Weakness in Internal Controls over Compliance
This is a repeat of prior year finding #2022-006.
Criteria/Condition: Federal regulations 2 CFR 200.328 - 200.329 provide that required reporting under the federal program must be completed timely and accurately. The federal award agreement includes specific report filing due dates. Segregation of duties is also a key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction or process from beginning to end. We noted during testing of sixteen different required reports that five of these reports tested were not filed in a timely manner. There were also no review procedures in place surrounding these reports.
Cause/Context: Controls were not in place to ensure timely reporting. Only one individual was involved in the reporting process for the reports. A total of five of the reports tested were submitted more than ten days late.
Effect: A lack of controls could result in late or failed reporting.
Recommendation: We recommend the Organization establish procedures and controls to ensure financial and performance reports are filed timely.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will ensure that all federal award reports are filed in a timely manner. The Organization is in the process of posting a new position, Director of Grants and Compliance. The individual in this new role will be responsible for tracking report due dates and working with the individuals responsible for the content of these reports to ensure the information is accurate and on time. In situations where the Director of Grants and Compliance is responsible for gathering the data for required reporting, the data will be reviewed by either the CFO or CEO prior to submission of the report.
U.S. Department of Justice
Crime Victim Assistance – Assistance #16.575
#2023-009 – Major Federal Award Finding – Cash Management
Nature of Finding: Compliance Finding Cash Management and Significant Deficiency in Internal Controls over Compliance
Criteria/Condition: 2 CFR 200.305 requires that non-federal entities must minimize the time elapsing between the transfer of federal funds to the non-federal entity and the subsequent disbursement of the funds by the non-federal entity for program costs. The Organization did not have proper controls in place to verify that specific vendor invoices were paid within a reasonable amount of time of requesting reimbursement for the expenditures.
Questioned Costs: $2,381
Identification of How Questioned Costs Were Computed: The issues of noncompliance related to cash management was limited to one vendor that was not paid within a reasonable amount of time of being reimbursed for the costs. This was determined to be an isolated incident. Questioned costs include the two invoices that were charged to the grant for this vendor during the year ended September 30, 2023 and were not paid to the vendor within a reasonable amount of time of being reimbursed for the expenditures.
Cause/Context: Controls were not in place to ensure expenditures were paid to the vendor prior to requesting reimbursements. This circumstance was determined to be an isolated incident due to the unique nature of the vendor invoices. The Organization was withholding payment to the vendor until it determined that both invoices were proper.
Effect: The lack of controls could result in requests for reimbursement being submitted for unpaid expenditures.
Recommendation: We recommend the Organization establish procedures and incorporate controls to review that expenditures are paid prior to submitting requests for reimbursement.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
Each month, an aged open accounts payable report will be produced as part of the month end closing. Invoices that are past due will be paid in the following batch of payments (which are typically run weekly). If it is determined that the invoice is not being paid for a valid reason, it will be removed from accounts payable at that time.
U.S. Department of Justice
Crime Victim Assistance – Assistance #16.575
#2023-009 – Major Federal Award Finding – Cash Management
Nature of Finding: Compliance Finding Cash Management and Significant Deficiency in Internal Controls over Compliance
Criteria/Condition: 2 CFR 200.305 requires that non-federal entities must minimize the time elapsing between the transfer of federal funds to the non-federal entity and the subsequent disbursement of the funds by the non-federal entity for program costs. The Organization did not have proper controls in place to verify that specific vendor invoices were paid within a reasonable amount of time of requesting reimbursement for the expenditures.
Questioned Costs: $2,381
Identification of How Questioned Costs Were Computed: The issues of noncompliance related to cash management was limited to one vendor that was not paid within a reasonable amount of time of being reimbursed for the costs. This was determined to be an isolated incident. Questioned costs include the two invoices that were charged to the grant for this vendor during the year ended September 30, 2023 and were not paid to the vendor within a reasonable amount of time of being reimbursed for the expenditures.
Cause/Context: Controls were not in place to ensure expenditures were paid to the vendor prior to requesting reimbursements. This circumstance was determined to be an isolated incident due to the unique nature of the vendor invoices. The Organization was withholding payment to the vendor until it determined that both invoices were proper.
Effect: The lack of controls could result in requests for reimbursement being submitted for unpaid expenditures.
Recommendation: We recommend the Organization establish procedures and incorporate controls to review that expenditures are paid prior to submitting requests for reimbursement.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
Each month, an aged open accounts payable report will be produced as part of the month end closing. Invoices that are past due will be paid in the following batch of payments (which are typically run weekly). If it is determined that the invoice is not being paid for a valid reason, it will be removed from accounts payable at that time.
#2023-010 – Major Federal Award Finding – Period of Performance
Nature of Finding: Compliance Finding Period of Performance and Material Weakness in Internal Controls over Compliance
Criteria/Condition: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance. The Organization did not have controls in place to verify that costs were being charged to the award in the correct period of performance.
Questioned Costs: $20,790
Identification of How Questioned Costs Were Computed: A sample of 40 non-payroll expenditures totaling approximately $48,000 was selected from a population of approximately $552,000 of non-payroll expenditures. An amount of $1,817 combined from two invoices that were charged to the Crime Victim Assistance program was related to the year ending September 30, 2024 and was inappropriately charged to the grant during 2023. Questioned costs are estimated by projecting the error identified in the sample tested to the population of non-payroll expenditures of the Crime Victim Assistance program.
Cause/Context: There are not proper controls in place to review invoices and assign them to the appropriate grant period. Two expenditures out of forty non-payroll related expenditures tested for the Crime Victim Assistance grant was for a contracted annual service that covered multiple performance periods but was billed in its entirety to the current fiscal year.
Effect: An overstatement of expenditures for the Crime Victim Assistance grant was reported in the current year.
Recommendation: We recommend procedures are established to review for proper grant period when recording transactions and creating monthly reimbursement requests.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures.
1. The Staff Accountant will review the period each expenditure is related to and record the invoice to the appropriate period when entering it into accounts payable. The month and year will be noted on the invoice.
2. The CFO will review the month and year noted by the Staff Accountant prior to entry into accounts payable.
U.S. Department of Homeland Security, U.S. Department of Justice, and U.S. Department of Health and Human Services
#2023-011 – Major Federal Award Finding
Nature of Finding: Significant Deficiency in Internal Controls over Compliance
This is a repeat of prior year finding #2022-007.
Criteria/Condition: Per 2 CFR 200.510(b), the auditee must prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee's financial statements, which must include the total federal awards expended, as determined in accordance with §200.502. For SEFA reporting, federal expenditures were not disclosed for one program and were overstated or understated for other programs.
Cause/Context: Expenditures for the Emergency Food and Shelter National Board Program were excluded from the client-prepared SEFA. There were various other grants with allocations between state and federal funding that were not presented properly on the SEFA. The SEFA presented has been adjusted for these errors.
Effect: Controls in place did not sufficiently ensure the completeness and accuracy of the SEFA.
Recommendation: We recommend the Organization enhance its procedures and controls to ensure data accumulated to prepare the SEFA is complete and accurate.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
The Schedule of Expenditures of Federal Awards (SEFA) will be reviewed for accuracy by either the CFO or CEO after it is produced, to ensure that all federal awards are included, and that the amounts on the schedule are accurate.
U.S. Department of Justice
Crime Victim Assistance – Assistance #16.575
#2023-008 – Major Federal Award Finding – Reporting
Nature of Finding: Compliance Finding Reporting and Material Weakness in Internal Controls over Compliance
This is a repeat of prior year finding #2022-006.
Criteria/Condition: Federal regulations 2 CFR 200.328 - 200.329 provide that required reporting under the federal program must be completed timely and accurately. The federal award agreement includes specific report filing due dates. Segregation of duties is also a key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction or process from beginning to end. We noted during testing of sixteen different required reports that five of these reports tested were not filed in a timely manner. There were also no review procedures in place surrounding these reports.
Cause/Context: Controls were not in place to ensure timely reporting. Only one individual was involved in the reporting process for the reports. A total of five of the reports tested were submitted more than ten days late.
Effect: A lack of controls could result in late or failed reporting.
Recommendation: We recommend the Organization establish procedures and controls to ensure financial and performance reports are filed timely.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will ensure that all federal award reports are filed in a timely manner. The Organization is in the process of posting a new position, Director of Grants and Compliance. The individual in this new role will be responsible for tracking report due dates and working with the individuals responsible for the content of these reports to ensure the information is accurate and on time. In situations where the Director of Grants and Compliance is responsible for gathering the data for required reporting, the data will be reviewed by either the CFO or CEO prior to submission of the report.
U.S. Department of Justice
Crime Victim Assistance – Assistance #16.575
#2023-009 – Major Federal Award Finding – Cash Management
Nature of Finding: Compliance Finding Cash Management and Significant Deficiency in Internal Controls over Compliance
Criteria/Condition: 2 CFR 200.305 requires that non-federal entities must minimize the time elapsing between the transfer of federal funds to the non-federal entity and the subsequent disbursement of the funds by the non-federal entity for program costs. The Organization did not have proper controls in place to verify that specific vendor invoices were paid within a reasonable amount of time of requesting reimbursement for the expenditures.
Questioned Costs: $2,381
Identification of How Questioned Costs Were Computed: The issues of noncompliance related to cash management was limited to one vendor that was not paid within a reasonable amount of time of being reimbursed for the costs. This was determined to be an isolated incident. Questioned costs include the two invoices that were charged to the grant for this vendor during the year ended September 30, 2023 and were not paid to the vendor within a reasonable amount of time of being reimbursed for the expenditures.
Cause/Context: Controls were not in place to ensure expenditures were paid to the vendor prior to requesting reimbursements. This circumstance was determined to be an isolated incident due to the unique nature of the vendor invoices. The Organization was withholding payment to the vendor until it determined that both invoices were proper.
Effect: The lack of controls could result in requests for reimbursement being submitted for unpaid expenditures.
Recommendation: We recommend the Organization establish procedures and incorporate controls to review that expenditures are paid prior to submitting requests for reimbursement.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
Each month, an aged open accounts payable report will be produced as part of the month end closing. Invoices that are past due will be paid in the following batch of payments (which are typically run weekly). If it is determined that the invoice is not being paid for a valid reason, it will be removed from accounts payable at that time.
U.S. Department of Justice
Crime Victim Assistance – Assistance #16.575
#2023-009 – Major Federal Award Finding – Cash Management
Nature of Finding: Compliance Finding Cash Management and Significant Deficiency in Internal Controls over Compliance
Criteria/Condition: 2 CFR 200.305 requires that non-federal entities must minimize the time elapsing between the transfer of federal funds to the non-federal entity and the subsequent disbursement of the funds by the non-federal entity for program costs. The Organization did not have proper controls in place to verify that specific vendor invoices were paid within a reasonable amount of time of requesting reimbursement for the expenditures.
Questioned Costs: $2,381
Identification of How Questioned Costs Were Computed: The issues of noncompliance related to cash management was limited to one vendor that was not paid within a reasonable amount of time of being reimbursed for the costs. This was determined to be an isolated incident. Questioned costs include the two invoices that were charged to the grant for this vendor during the year ended September 30, 2023 and were not paid to the vendor within a reasonable amount of time of being reimbursed for the expenditures.
Cause/Context: Controls were not in place to ensure expenditures were paid to the vendor prior to requesting reimbursements. This circumstance was determined to be an isolated incident due to the unique nature of the vendor invoices. The Organization was withholding payment to the vendor until it determined that both invoices were proper.
Effect: The lack of controls could result in requests for reimbursement being submitted for unpaid expenditures.
Recommendation: We recommend the Organization establish procedures and incorporate controls to review that expenditures are paid prior to submitting requests for reimbursement.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
Each month, an aged open accounts payable report will be produced as part of the month end closing. Invoices that are past due will be paid in the following batch of payments (which are typically run weekly). If it is determined that the invoice is not being paid for a valid reason, it will be removed from accounts payable at that time.
#2023-010 – Major Federal Award Finding – Period of Performance
Nature of Finding: Compliance Finding Period of Performance and Material Weakness in Internal Controls over Compliance
Criteria/Condition: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance. The Organization did not have controls in place to verify that costs were being charged to the award in the correct period of performance.
Questioned Costs: $20,790
Identification of How Questioned Costs Were Computed: A sample of 40 non-payroll expenditures totaling approximately $48,000 was selected from a population of approximately $552,000 of non-payroll expenditures. An amount of $1,817 combined from two invoices that were charged to the Crime Victim Assistance program was related to the year ending September 30, 2024 and was inappropriately charged to the grant during 2023. Questioned costs are estimated by projecting the error identified in the sample tested to the population of non-payroll expenditures of the Crime Victim Assistance program.
Cause/Context: There are not proper controls in place to review invoices and assign them to the appropriate grant period. Two expenditures out of forty non-payroll related expenditures tested for the Crime Victim Assistance grant was for a contracted annual service that covered multiple performance periods but was billed in its entirety to the current fiscal year.
Effect: An overstatement of expenditures for the Crime Victim Assistance grant was reported in the current year.
Recommendation: We recommend procedures are established to review for proper grant period when recording transactions and creating monthly reimbursement requests.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures.
1. The Staff Accountant will review the period each expenditure is related to and record the invoice to the appropriate period when entering it into accounts payable. The month and year will be noted on the invoice.
2. The CFO will review the month and year noted by the Staff Accountant prior to entry into accounts payable.
U.S. Department of Homeland Security, U.S. Department of Justice, and U.S. Department of Health and Human Services
#2023-011 – Major Federal Award Finding
Nature of Finding: Significant Deficiency in Internal Controls over Compliance
This is a repeat of prior year finding #2022-007.
Criteria/Condition: Per 2 CFR 200.510(b), the auditee must prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee's financial statements, which must include the total federal awards expended, as determined in accordance with §200.502. For SEFA reporting, federal expenditures were not disclosed for one program and were overstated or understated for other programs.
Cause/Context: Expenditures for the Emergency Food and Shelter National Board Program were excluded from the client-prepared SEFA. There were various other grants with allocations between state and federal funding that were not presented properly on the SEFA. The SEFA presented has been adjusted for these errors.
Effect: Controls in place did not sufficiently ensure the completeness and accuracy of the SEFA.
Recommendation: We recommend the Organization enhance its procedures and controls to ensure data accumulated to prepare the SEFA is complete and accurate.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
The Schedule of Expenditures of Federal Awards (SEFA) will be reviewed for accuracy by either the CFO or CEO after it is produced, to ensure that all federal awards are included, and that the amounts on the schedule are accurate.
U.S. Department of Justice
Crime Victim Assistance – Assistance #16.575
#2023-008 – Major Federal Award Finding – Reporting
Nature of Finding: Compliance Finding Reporting and Material Weakness in Internal Controls over Compliance
This is a repeat of prior year finding #2022-006.
Criteria/Condition: Federal regulations 2 CFR 200.328 - 200.329 provide that required reporting under the federal program must be completed timely and accurately. The federal award agreement includes specific report filing due dates. Segregation of duties is also a key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction or process from beginning to end. We noted during testing of sixteen different required reports that five of these reports tested were not filed in a timely manner. There were also no review procedures in place surrounding these reports.
Cause/Context: Controls were not in place to ensure timely reporting. Only one individual was involved in the reporting process for the reports. A total of five of the reports tested were submitted more than ten days late.
Effect: A lack of controls could result in late or failed reporting.
Recommendation: We recommend the Organization establish procedures and controls to ensure financial and performance reports are filed timely.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will ensure that all federal award reports are filed in a timely manner. The Organization is in the process of posting a new position, Director of Grants and Compliance. The individual in this new role will be responsible for tracking report due dates and working with the individuals responsible for the content of these reports to ensure the information is accurate and on time. In situations where the Director of Grants and Compliance is responsible for gathering the data for required reporting, the data will be reviewed by either the CFO or CEO prior to submission of the report.
U.S. Department of Justice
Crime Victim Assistance – Assistance #16.575
#2023-009 – Major Federal Award Finding – Cash Management
Nature of Finding: Compliance Finding Cash Management and Significant Deficiency in Internal Controls over Compliance
Criteria/Condition: 2 CFR 200.305 requires that non-federal entities must minimize the time elapsing between the transfer of federal funds to the non-federal entity and the subsequent disbursement of the funds by the non-federal entity for program costs. The Organization did not have proper controls in place to verify that specific vendor invoices were paid within a reasonable amount of time of requesting reimbursement for the expenditures.
Questioned Costs: $2,381
Identification of How Questioned Costs Were Computed: The issues of noncompliance related to cash management was limited to one vendor that was not paid within a reasonable amount of time of being reimbursed for the costs. This was determined to be an isolated incident. Questioned costs include the two invoices that were charged to the grant for this vendor during the year ended September 30, 2023 and were not paid to the vendor within a reasonable amount of time of being reimbursed for the expenditures.
Cause/Context: Controls were not in place to ensure expenditures were paid to the vendor prior to requesting reimbursements. This circumstance was determined to be an isolated incident due to the unique nature of the vendor invoices. The Organization was withholding payment to the vendor until it determined that both invoices were proper.
Effect: The lack of controls could result in requests for reimbursement being submitted for unpaid expenditures.
Recommendation: We recommend the Organization establish procedures and incorporate controls to review that expenditures are paid prior to submitting requests for reimbursement.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
Each month, an aged open accounts payable report will be produced as part of the month end closing. Invoices that are past due will be paid in the following batch of payments (which are typically run weekly). If it is determined that the invoice is not being paid for a valid reason, it will be removed from accounts payable at that time.
U.S. Department of Justice
Crime Victim Assistance – Assistance #16.575
#2023-009 – Major Federal Award Finding – Cash Management
Nature of Finding: Compliance Finding Cash Management and Significant Deficiency in Internal Controls over Compliance
Criteria/Condition: 2 CFR 200.305 requires that non-federal entities must minimize the time elapsing between the transfer of federal funds to the non-federal entity and the subsequent disbursement of the funds by the non-federal entity for program costs. The Organization did not have proper controls in place to verify that specific vendor invoices were paid within a reasonable amount of time of requesting reimbursement for the expenditures.
Questioned Costs: $2,381
Identification of How Questioned Costs Were Computed: The issues of noncompliance related to cash management was limited to one vendor that was not paid within a reasonable amount of time of being reimbursed for the costs. This was determined to be an isolated incident. Questioned costs include the two invoices that were charged to the grant for this vendor during the year ended September 30, 2023 and were not paid to the vendor within a reasonable amount of time of being reimbursed for the expenditures.
Cause/Context: Controls were not in place to ensure expenditures were paid to the vendor prior to requesting reimbursements. This circumstance was determined to be an isolated incident due to the unique nature of the vendor invoices. The Organization was withholding payment to the vendor until it determined that both invoices were proper.
Effect: The lack of controls could result in requests for reimbursement being submitted for unpaid expenditures.
Recommendation: We recommend the Organization establish procedures and incorporate controls to review that expenditures are paid prior to submitting requests for reimbursement.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
Each month, an aged open accounts payable report will be produced as part of the month end closing. Invoices that are past due will be paid in the following batch of payments (which are typically run weekly). If it is determined that the invoice is not being paid for a valid reason, it will be removed from accounts payable at that time.
#2023-010 – Major Federal Award Finding – Period of Performance
Nature of Finding: Compliance Finding Period of Performance and Material Weakness in Internal Controls over Compliance
Criteria/Condition: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance. The Organization did not have controls in place to verify that costs were being charged to the award in the correct period of performance.
Questioned Costs: $20,790
Identification of How Questioned Costs Were Computed: A sample of 40 non-payroll expenditures totaling approximately $48,000 was selected from a population of approximately $552,000 of non-payroll expenditures. An amount of $1,817 combined from two invoices that were charged to the Crime Victim Assistance program was related to the year ending September 30, 2024 and was inappropriately charged to the grant during 2023. Questioned costs are estimated by projecting the error identified in the sample tested to the population of non-payroll expenditures of the Crime Victim Assistance program.
Cause/Context: There are not proper controls in place to review invoices and assign them to the appropriate grant period. Two expenditures out of forty non-payroll related expenditures tested for the Crime Victim Assistance grant was for a contracted annual service that covered multiple performance periods but was billed in its entirety to the current fiscal year.
Effect: An overstatement of expenditures for the Crime Victim Assistance grant was reported in the current year.
Recommendation: We recommend procedures are established to review for proper grant period when recording transactions and creating monthly reimbursement requests.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures.
1. The Staff Accountant will review the period each expenditure is related to and record the invoice to the appropriate period when entering it into accounts payable. The month and year will be noted on the invoice.
2. The CFO will review the month and year noted by the Staff Accountant prior to entry into accounts payable.
U.S. Department of Homeland Security, U.S. Department of Justice, and U.S. Department of Health and Human Services
#2023-011 – Major Federal Award Finding
Nature of Finding: Significant Deficiency in Internal Controls over Compliance
This is a repeat of prior year finding #2022-007.
Criteria/Condition: Per 2 CFR 200.510(b), the auditee must prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee's financial statements, which must include the total federal awards expended, as determined in accordance with §200.502. For SEFA reporting, federal expenditures were not disclosed for one program and were overstated or understated for other programs.
Cause/Context: Expenditures for the Emergency Food and Shelter National Board Program were excluded from the client-prepared SEFA. There were various other grants with allocations between state and federal funding that were not presented properly on the SEFA. The SEFA presented has been adjusted for these errors.
Effect: Controls in place did not sufficiently ensure the completeness and accuracy of the SEFA.
Recommendation: We recommend the Organization enhance its procedures and controls to ensure data accumulated to prepare the SEFA is complete and accurate.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
The Schedule of Expenditures of Federal Awards (SEFA) will be reviewed for accuracy by either the CFO or CEO after it is produced, to ensure that all federal awards are included, and that the amounts on the schedule are accurate.
U.S. Department of Homeland Security, U.S. Department of Justice, and U.S. Department of Health and Human Services
#2023-011 – Major Federal Award Finding
Nature of Finding: Significant Deficiency in Internal Controls over Compliance
This is a repeat of prior year finding #2022-007.
Criteria/Condition: Per 2 CFR 200.510(b), the auditee must prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee's financial statements, which must include the total federal awards expended, as determined in accordance with §200.502. For SEFA reporting, federal expenditures were not disclosed for one program and were overstated or understated for other programs.
Cause/Context: Expenditures for the Emergency Food and Shelter National Board Program were excluded from the client-prepared SEFA. There were various other grants with allocations between state and federal funding that were not presented properly on the SEFA. The SEFA presented has been adjusted for these errors.
Effect: Controls in place did not sufficiently ensure the completeness and accuracy of the SEFA.
Recommendation: We recommend the Organization enhance its procedures and controls to ensure data accumulated to prepare the SEFA is complete and accurate.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
The Schedule of Expenditures of Federal Awards (SEFA) will be reviewed for accuracy by either the CFO or CEO after it is produced, to ensure that all federal awards are included, and that the amounts on the schedule are accurate.
U.S. Department of Homeland Security, U.S. Department of Justice, and U.S. Department of Health and Human Services
#2023-011 – Major Federal Award Finding
Nature of Finding: Significant Deficiency in Internal Controls over Compliance
This is a repeat of prior year finding #2022-007.
Criteria/Condition: Per 2 CFR 200.510(b), the auditee must prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee's financial statements, which must include the total federal awards expended, as determined in accordance with §200.502. For SEFA reporting, federal expenditures were not disclosed for one program and were overstated or understated for other programs.
Cause/Context: Expenditures for the Emergency Food and Shelter National Board Program were excluded from the client-prepared SEFA. There were various other grants with allocations between state and federal funding that were not presented properly on the SEFA. The SEFA presented has been adjusted for these errors.
Effect: Controls in place did not sufficiently ensure the completeness and accuracy of the SEFA.
Recommendation: We recommend the Organization enhance its procedures and controls to ensure data accumulated to prepare the SEFA is complete and accurate.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
The Schedule of Expenditures of Federal Awards (SEFA) will be reviewed for accuracy by either the CFO or CEO after it is produced, to ensure that all federal awards are included, and that the amounts on the schedule are accurate.
U.S. Department of Homeland Security, U.S. Department of Justice, and U.S. Department of Health and Human Services
#2023-011 – Major Federal Award Finding
Nature of Finding: Significant Deficiency in Internal Controls over Compliance
This is a repeat of prior year finding #2022-007.
Criteria/Condition: Per 2 CFR 200.510(b), the auditee must prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee's financial statements, which must include the total federal awards expended, as determined in accordance with §200.502. For SEFA reporting, federal expenditures were not disclosed for one program and were overstated or understated for other programs.
Cause/Context: Expenditures for the Emergency Food and Shelter National Board Program were excluded from the client-prepared SEFA. There were various other grants with allocations between state and federal funding that were not presented properly on the SEFA. The SEFA presented has been adjusted for these errors.
Effect: Controls in place did not sufficiently ensure the completeness and accuracy of the SEFA.
Recommendation: We recommend the Organization enhance its procedures and controls to ensure data accumulated to prepare the SEFA is complete and accurate.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
The Schedule of Expenditures of Federal Awards (SEFA) will be reviewed for accuracy by either the CFO or CEO after it is produced, to ensure that all federal awards are included, and that the amounts on the schedule are accurate.
U.S. Department of Homeland Security, U.S. Department of Justice, and U.S. Department of Health and Human Services
#2023-011 – Major Federal Award Finding
Nature of Finding: Significant Deficiency in Internal Controls over Compliance
This is a repeat of prior year finding #2022-007.
Criteria/Condition: Per 2 CFR 200.510(b), the auditee must prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee's financial statements, which must include the total federal awards expended, as determined in accordance with §200.502. For SEFA reporting, federal expenditures were not disclosed for one program and were overstated or understated for other programs.
Cause/Context: Expenditures for the Emergency Food and Shelter National Board Program were excluded from the client-prepared SEFA. There were various other grants with allocations between state and federal funding that were not presented properly on the SEFA. The SEFA presented has been adjusted for these errors.
Effect: Controls in place did not sufficiently ensure the completeness and accuracy of the SEFA.
Recommendation: We recommend the Organization enhance its procedures and controls to ensure data accumulated to prepare the SEFA is complete and accurate.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
The Schedule of Expenditures of Federal Awards (SEFA) will be reviewed for accuracy by either the CFO or CEO after it is produced, to ensure that all federal awards are included, and that the amounts on the schedule are accurate.
U.S. Department of Homeland Security, U.S. Department of Justice, and U.S. Department of Health and Human Services
#2023-011 – Major Federal Award Finding
Nature of Finding: Significant Deficiency in Internal Controls over Compliance
This is a repeat of prior year finding #2022-007.
Criteria/Condition: Per 2 CFR 200.510(b), the auditee must prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee's financial statements, which must include the total federal awards expended, as determined in accordance with §200.502. For SEFA reporting, federal expenditures were not disclosed for one program and were overstated or understated for other programs.
Cause/Context: Expenditures for the Emergency Food and Shelter National Board Program were excluded from the client-prepared SEFA. There were various other grants with allocations between state and federal funding that were not presented properly on the SEFA. The SEFA presented has been adjusted for these errors.
Effect: Controls in place did not sufficiently ensure the completeness and accuracy of the SEFA.
Recommendation: We recommend the Organization enhance its procedures and controls to ensure data accumulated to prepare the SEFA is complete and accurate.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
The Schedule of Expenditures of Federal Awards (SEFA) will be reviewed for accuracy by either the CFO or CEO after it is produced, to ensure that all federal awards are included, and that the amounts on the schedule are accurate.
#2023-004 – Material Weakness: Independent Review and Approval
Condition and Criteria: Independent reviews and approvals are not performed for all significant accounting activities. A procedure should be in place for independent reviews and approvals of significant accounting activities. For all activities, no one individual should have access that allows initiating, recording, authorizing, and reconciling a transaction.
Cause/Context: The following transactions are performed without independent review and approval:
• Journal entries are posted without a review or approval process.
• Formal review of payroll registers is not documented.
• Invoices are not regularly reviewed and approved by appropriate department directors. Invoices are also entered into the general ledger with no independent review of the entry.
• Percentages used to allocate expenses across grants are not reviewed on at least an annual basis.
• Matching amounts required for grants are not independently tracked and reviewed to ensure compliance.
Effect: Unauthorized, erroneous, or inappropriate transactions could occur and go unnoticed.
Recommendation: The Organization should establish review procedures such that all transactions have proper approval.Views of Responsible Officials and Planned Corrective Actions:
The YWCA will implement the following changes in its accounting procedures:
1. Journal entries will be drafted by the Staff Accountant and reviewed by the CFO prior to being posted to the general ledger. The end-of-month-journal-entry spreadsheets will have spaces added for the CFO to indicate approval and date approved.
2. Payroll registers will be reviewed by the CFO each payroll. The end-of-month payroll entry (which encompasses all the payroll entries for the month) will be reviewed by the CFO prior to being uploaded to the MIP accounting software.
3. All invoices will be approved by the appropriate program director and account distribution will be reviewed by the CFO prior to entry into the accounts payable system. 4. Percentages used to allocate expenses across grants will be reviewed and updated annually at the beginning of the fiscal year. The allocation will be approved by the CEO.
5. Matching amounts for grants will be tracked and documented with supporting documentation by the Director of Finance and saved in the appropriate folder within the Finance SharePoint folder
#2023-004 – Material Weakness: Independent Review and Approval
Condition and Criteria: Independent reviews and approvals are not performed for all significant accounting activities. A procedure should be in place for independent reviews and approvals of significant accounting activities. For all activities, no one individual should have access that allows initiating, recording, authorizing, and reconciling a transaction.
Cause/Context: The following transactions are performed without independent review and approval:
• Journal entries are posted without a review or approval process.
• Formal review of payroll registers is not documented.
• Invoices are not regularly reviewed and approved by appropriate department directors. Invoices are also entered into the general ledger with no independent review of the entry.
• Percentages used to allocate expenses across grants are not reviewed on at least an annual basis.
• Matching amounts required for grants are not independently tracked and reviewed to ensure compliance.
Effect: Unauthorized, erroneous, or inappropriate transactions could occur and go unnoticed.
Recommendation: The Organization should establish review procedures such that all transactions have proper approval.Views of Responsible Officials and Planned Corrective Actions:
The YWCA will implement the following changes in its accounting procedures:
1. Journal entries will be drafted by the Staff Accountant and reviewed by the CFO prior to being posted to the general ledger. The end-of-month-journal-entry spreadsheets will have spaces added for the CFO to indicate approval and date approved.
2. Payroll registers will be reviewed by the CFO each payroll. The end-of-month payroll entry (which encompasses all the payroll entries for the month) will be reviewed by the CFO prior to being uploaded to the MIP accounting software.
3. All invoices will be approved by the appropriate program director and account distribution will be reviewed by the CFO prior to entry into the accounts payable system. 4. Percentages used to allocate expenses across grants will be reviewed and updated annually at the beginning of the fiscal year. The allocation will be approved by the CEO.
5. Matching amounts for grants will be tracked and documented with supporting documentation by the Director of Finance and saved in the appropriate folder within the Finance SharePoint folder
#2023-004 – Material Weakness: Independent Review and Approval
Condition and Criteria: Independent reviews and approvals are not performed for all significant accounting activities. A procedure should be in place for independent reviews and approvals of significant accounting activities. For all activities, no one individual should have access that allows initiating, recording, authorizing, and reconciling a transaction.
Cause/Context: The following transactions are performed without independent review and approval:
• Journal entries are posted without a review or approval process.
• Formal review of payroll registers is not documented.
• Invoices are not regularly reviewed and approved by appropriate department directors. Invoices are also entered into the general ledger with no independent review of the entry.
• Percentages used to allocate expenses across grants are not reviewed on at least an annual basis.
• Matching amounts required for grants are not independently tracked and reviewed to ensure compliance.
Effect: Unauthorized, erroneous, or inappropriate transactions could occur and go unnoticed.
Recommendation: The Organization should establish review procedures such that all transactions have proper approval.Views of Responsible Officials and Planned Corrective Actions:
The YWCA will implement the following changes in its accounting procedures:
1. Journal entries will be drafted by the Staff Accountant and reviewed by the CFO prior to being posted to the general ledger. The end-of-month-journal-entry spreadsheets will have spaces added for the CFO to indicate approval and date approved.
2. Payroll registers will be reviewed by the CFO each payroll. The end-of-month payroll entry (which encompasses all the payroll entries for the month) will be reviewed by the CFO prior to being uploaded to the MIP accounting software.
3. All invoices will be approved by the appropriate program director and account distribution will be reviewed by the CFO prior to entry into the accounts payable system. 4. Percentages used to allocate expenses across grants will be reviewed and updated annually at the beginning of the fiscal year. The allocation will be approved by the CEO.
5. Matching amounts for grants will be tracked and documented with supporting documentation by the Director of Finance and saved in the appropriate folder within the Finance SharePoint folder
#2023-004 – Material Weakness: Independent Review and Approval
Condition and Criteria: Independent reviews and approvals are not performed for all significant accounting activities. A procedure should be in place for independent reviews and approvals of significant accounting activities. For all activities, no one individual should have access that allows initiating, recording, authorizing, and reconciling a transaction.
Cause/Context: The following transactions are performed without independent review and approval:
• Journal entries are posted without a review or approval process.
• Formal review of payroll registers is not documented.
• Invoices are not regularly reviewed and approved by appropriate department directors. Invoices are also entered into the general ledger with no independent review of the entry.
• Percentages used to allocate expenses across grants are not reviewed on at least an annual basis.
• Matching amounts required for grants are not independently tracked and reviewed to ensure compliance.
Effect: Unauthorized, erroneous, or inappropriate transactions could occur and go unnoticed.
Recommendation: The Organization should establish review procedures such that all transactions have proper approval.Views of Responsible Officials and Planned Corrective Actions:
The YWCA will implement the following changes in its accounting procedures:
1. Journal entries will be drafted by the Staff Accountant and reviewed by the CFO prior to being posted to the general ledger. The end-of-month-journal-entry spreadsheets will have spaces added for the CFO to indicate approval and date approved.
2. Payroll registers will be reviewed by the CFO each payroll. The end-of-month payroll entry (which encompasses all the payroll entries for the month) will be reviewed by the CFO prior to being uploaded to the MIP accounting software.
3. All invoices will be approved by the appropriate program director and account distribution will be reviewed by the CFO prior to entry into the accounts payable system. 4. Percentages used to allocate expenses across grants will be reviewed and updated annually at the beginning of the fiscal year. The allocation will be approved by the CEO.
5. Matching amounts for grants will be tracked and documented with supporting documentation by the Director of Finance and saved in the appropriate folder within the Finance SharePoint folder
#2023-004 – Material Weakness: Independent Review and Approval
Condition and Criteria: Independent reviews and approvals are not performed for all significant accounting activities. A procedure should be in place for independent reviews and approvals of significant accounting activities. For all activities, no one individual should have access that allows initiating, recording, authorizing, and reconciling a transaction.
Cause/Context: The following transactions are performed without independent review and approval:
• Journal entries are posted without a review or approval process.
• Formal review of payroll registers is not documented.
• Invoices are not regularly reviewed and approved by appropriate department directors. Invoices are also entered into the general ledger with no independent review of the entry.
• Percentages used to allocate expenses across grants are not reviewed on at least an annual basis.
• Matching amounts required for grants are not independently tracked and reviewed to ensure compliance.
Effect: Unauthorized, erroneous, or inappropriate transactions could occur and go unnoticed.
Recommendation: The Organization should establish review procedures such that all transactions have proper approval.Views of Responsible Officials and Planned Corrective Actions:
The YWCA will implement the following changes in its accounting procedures:
1. Journal entries will be drafted by the Staff Accountant and reviewed by the CFO prior to being posted to the general ledger. The end-of-month-journal-entry spreadsheets will have spaces added for the CFO to indicate approval and date approved.
2. Payroll registers will be reviewed by the CFO each payroll. The end-of-month payroll entry (which encompasses all the payroll entries for the month) will be reviewed by the CFO prior to being uploaded to the MIP accounting software.
3. All invoices will be approved by the appropriate program director and account distribution will be reviewed by the CFO prior to entry into the accounts payable system. 4. Percentages used to allocate expenses across grants will be reviewed and updated annually at the beginning of the fiscal year. The allocation will be approved by the CEO.
5. Matching amounts for grants will be tracked and documented with supporting documentation by the Director of Finance and saved in the appropriate folder within the Finance SharePoint folder
#2023-004 – Material Weakness: Independent Review and Approval
Condition and Criteria: Independent reviews and approvals are not performed for all significant accounting activities. A procedure should be in place for independent reviews and approvals of significant accounting activities. For all activities, no one individual should have access that allows initiating, recording, authorizing, and reconciling a transaction.
Cause/Context: The following transactions are performed without independent review and approval:
• Journal entries are posted without a review or approval process.
• Formal review of payroll registers is not documented.
• Invoices are not regularly reviewed and approved by appropriate department directors. Invoices are also entered into the general ledger with no independent review of the entry.
• Percentages used to allocate expenses across grants are not reviewed on at least an annual basis.
• Matching amounts required for grants are not independently tracked and reviewed to ensure compliance.
Effect: Unauthorized, erroneous, or inappropriate transactions could occur and go unnoticed.
Recommendation: The Organization should establish review procedures such that all transactions have proper approval.Views of Responsible Officials and Planned Corrective Actions:
The YWCA will implement the following changes in its accounting procedures:
1. Journal entries will be drafted by the Staff Accountant and reviewed by the CFO prior to being posted to the general ledger. The end-of-month-journal-entry spreadsheets will have spaces added for the CFO to indicate approval and date approved.
2. Payroll registers will be reviewed by the CFO each payroll. The end-of-month payroll entry (which encompasses all the payroll entries for the month) will be reviewed by the CFO prior to being uploaded to the MIP accounting software.
3. All invoices will be approved by the appropriate program director and account distribution will be reviewed by the CFO prior to entry into the accounts payable system. 4. Percentages used to allocate expenses across grants will be reviewed and updated annually at the beginning of the fiscal year. The allocation will be approved by the CEO.
5. Matching amounts for grants will be tracked and documented with supporting documentation by the Director of Finance and saved in the appropriate folder within the Finance SharePoint folder
#2023-004 – Material Weakness: Independent Review and Approval
Condition and Criteria: Independent reviews and approvals are not performed for all significant accounting activities. A procedure should be in place for independent reviews and approvals of significant accounting activities. For all activities, no one individual should have access that allows initiating, recording, authorizing, and reconciling a transaction.
Cause/Context: The following transactions are performed without independent review and approval:
• Journal entries are posted without a review or approval process.
• Formal review of payroll registers is not documented.
• Invoices are not regularly reviewed and approved by appropriate department directors. Invoices are also entered into the general ledger with no independent review of the entry.
• Percentages used to allocate expenses across grants are not reviewed on at least an annual basis.
• Matching amounts required for grants are not independently tracked and reviewed to ensure compliance.
Effect: Unauthorized, erroneous, or inappropriate transactions could occur and go unnoticed.
Recommendation: The Organization should establish review procedures such that all transactions have proper approval.Views of Responsible Officials and Planned Corrective Actions:
The YWCA will implement the following changes in its accounting procedures:
1. Journal entries will be drafted by the Staff Accountant and reviewed by the CFO prior to being posted to the general ledger. The end-of-month-journal-entry spreadsheets will have spaces added for the CFO to indicate approval and date approved.
2. Payroll registers will be reviewed by the CFO each payroll. The end-of-month payroll entry (which encompasses all the payroll entries for the month) will be reviewed by the CFO prior to being uploaded to the MIP accounting software.
3. All invoices will be approved by the appropriate program director and account distribution will be reviewed by the CFO prior to entry into the accounts payable system. 4. Percentages used to allocate expenses across grants will be reviewed and updated annually at the beginning of the fiscal year. The allocation will be approved by the CEO.
5. Matching amounts for grants will be tracked and documented with supporting documentation by the Director of Finance and saved in the appropriate folder within the Finance SharePoint folder
#2023-004 – Material Weakness: Independent Review and Approval
Condition and Criteria: Independent reviews and approvals are not performed for all significant accounting activities. A procedure should be in place for independent reviews and approvals of significant accounting activities. For all activities, no one individual should have access that allows initiating, recording, authorizing, and reconciling a transaction.
Cause/Context: The following transactions are performed without independent review and approval:
• Journal entries are posted without a review or approval process.
• Formal review of payroll registers is not documented.
• Invoices are not regularly reviewed and approved by appropriate department directors. Invoices are also entered into the general ledger with no independent review of the entry.
• Percentages used to allocate expenses across grants are not reviewed on at least an annual basis.
• Matching amounts required for grants are not independently tracked and reviewed to ensure compliance.
Effect: Unauthorized, erroneous, or inappropriate transactions could occur and go unnoticed.
Recommendation: The Organization should establish review procedures such that all transactions have proper approval.Views of Responsible Officials and Planned Corrective Actions:
The YWCA will implement the following changes in its accounting procedures:
1. Journal entries will be drafted by the Staff Accountant and reviewed by the CFO prior to being posted to the general ledger. The end-of-month-journal-entry spreadsheets will have spaces added for the CFO to indicate approval and date approved.
2. Payroll registers will be reviewed by the CFO each payroll. The end-of-month payroll entry (which encompasses all the payroll entries for the month) will be reviewed by the CFO prior to being uploaded to the MIP accounting software.
3. All invoices will be approved by the appropriate program director and account distribution will be reviewed by the CFO prior to entry into the accounts payable system. 4. Percentages used to allocate expenses across grants will be reviewed and updated annually at the beginning of the fiscal year. The allocation will be approved by the CEO.
5. Matching amounts for grants will be tracked and documented with supporting documentation by the Director of Finance and saved in the appropriate folder within the Finance SharePoint folder
#2023-004 – Material Weakness: Independent Review and Approval
Condition and Criteria: Independent reviews and approvals are not performed for all significant accounting activities. A procedure should be in place for independent reviews and approvals of significant accounting activities. For all activities, no one individual should have access that allows initiating, recording, authorizing, and reconciling a transaction.
Cause/Context: The following transactions are performed without independent review and approval:
• Journal entries are posted without a review or approval process.
• Formal review of payroll registers is not documented.
• Invoices are not regularly reviewed and approved by appropriate department directors. Invoices are also entered into the general ledger with no independent review of the entry.
• Percentages used to allocate expenses across grants are not reviewed on at least an annual basis.
• Matching amounts required for grants are not independently tracked and reviewed to ensure compliance.
Effect: Unauthorized, erroneous, or inappropriate transactions could occur and go unnoticed.
Recommendation: The Organization should establish review procedures such that all transactions have proper approval.Views of Responsible Officials and Planned Corrective Actions:
The YWCA will implement the following changes in its accounting procedures:
1. Journal entries will be drafted by the Staff Accountant and reviewed by the CFO prior to being posted to the general ledger. The end-of-month-journal-entry spreadsheets will have spaces added for the CFO to indicate approval and date approved.
2. Payroll registers will be reviewed by the CFO each payroll. The end-of-month payroll entry (which encompasses all the payroll entries for the month) will be reviewed by the CFO prior to being uploaded to the MIP accounting software.
3. All invoices will be approved by the appropriate program director and account distribution will be reviewed by the CFO prior to entry into the accounts payable system. 4. Percentages used to allocate expenses across grants will be reviewed and updated annually at the beginning of the fiscal year. The allocation will be approved by the CEO.
5. Matching amounts for grants will be tracked and documented with supporting documentation by the Director of Finance and saved in the appropriate folder within the Finance SharePoint folder
#2023-004 – Material Weakness: Independent Review and Approval
Condition and Criteria: Independent reviews and approvals are not performed for all significant accounting activities. A procedure should be in place for independent reviews and approvals of significant accounting activities. For all activities, no one individual should have access that allows initiating, recording, authorizing, and reconciling a transaction.
Cause/Context: The following transactions are performed without independent review and approval:
• Journal entries are posted without a review or approval process.
• Formal review of payroll registers is not documented.
• Invoices are not regularly reviewed and approved by appropriate department directors. Invoices are also entered into the general ledger with no independent review of the entry.
• Percentages used to allocate expenses across grants are not reviewed on at least an annual basis.
• Matching amounts required for grants are not independently tracked and reviewed to ensure compliance.
Effect: Unauthorized, erroneous, or inappropriate transactions could occur and go unnoticed.
Recommendation: The Organization should establish review procedures such that all transactions have proper approval.Views of Responsible Officials and Planned Corrective Actions:
The YWCA will implement the following changes in its accounting procedures:
1. Journal entries will be drafted by the Staff Accountant and reviewed by the CFO prior to being posted to the general ledger. The end-of-month-journal-entry spreadsheets will have spaces added for the CFO to indicate approval and date approved.
2. Payroll registers will be reviewed by the CFO each payroll. The end-of-month payroll entry (which encompasses all the payroll entries for the month) will be reviewed by the CFO prior to being uploaded to the MIP accounting software.
3. All invoices will be approved by the appropriate program director and account distribution will be reviewed by the CFO prior to entry into the accounts payable system. 4. Percentages used to allocate expenses across grants will be reviewed and updated annually at the beginning of the fiscal year. The allocation will be approved by the CEO.
5. Matching amounts for grants will be tracked and documented with supporting documentation by the Director of Finance and saved in the appropriate folder within the Finance SharePoint folder
U.S. Department of Housing and Urban Development
Continuum of Care – Assistance #14.267
#2023-005 – Major Federal Award Finding – Special Tests and Provisions
Nature of Finding: Compliance Finding Special Tests and Provisions and Significant Deficiency in Internal Controls over Compliance
This is a repeat of prior year finding #2022-005.
Criteria/Condition: Per 24 CFR 578.49, rent paid must be reasonable in relation to rents being charged in the area for comparable space. The Organization did not have controls in place to verify that rent paid is reasonable in relation to rents being charged in the area for comparable space.
Cause/Context: Controls were not in place to ensure rent reasonableness. For the rent payments tested, we noted that management's conclusions for rent reasonableness was not documented.
Effect: A lack of controls could result in questioned costs and an inappropriate amount of rent payments being charged to the federal program.
Recommendation: We recommend management establish procedures and controls to require that evidence of review for rent reasonableness be maintained, and that the related conclusions are documented.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
For each client in the HEAL program, where the Organization pays rent for the client, a rent reasonableness form will be completed by the HEAL program staff and approved by the HEAL Program Director and Senior Director. The form will be saved in the client’s file within the Bizstream client management program. The rent reasonableness form will also be submitted to the finance department prior to, or along with, a request for the client’s first rent payment.
U.S. Department of Housing and Urban Development
Continuum of Care – Assistance #14.267
#2023-006 – Major Federal Award Finding - Period of Performance Nature of Finding: Compliance Finding Period of Performance and Material Weakness in Internal Controls over Compliance
Criteria/Condition: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance. The Organization did not have controls in place to verify that costs were being charged to the award in the correct period of performance.
Questioned Costs: $4,035
Identification of How Questioned Costs Were Computed: A sample of 40 non-payroll expenditures totaling approximately $49,000 was selected from a population of approximately $764,000 of non-payroll expenditures. An amount of $263 from an invoice that was selected for testing of non-payroll expenditures charged to the Continuum of Care program was related to the year ending September 30, 2024 and was inappropriately charged to the grant during 2023. Questioned costs are estimated by projecting the error identified in the sample tested to the population of non-payroll expenditures of the Continuum of Care program.
Cause/Context: There are not proper controls in place to review invoices and assign them to the appropriate grant period. One expenditure out of forty non-payroll related expenditures tested for the Continuum of Care grant was for a contracted monthly service that covered multiple performance periods but was billed in its entirety to the current fiscal year.
Effect: An overstatement of expenditures for the Continuum of Care grant was reported in the current year.
Recommendation: We recommend procedures are established to review for proper grant period when recording transactions and creating monthly reimbursement requests.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
1. The Staff Accountant will review the period each expenditure is related to and record the invoice to the appropriate period when entering it into accounts payable. The month and year will be noted on the invoice.
2. The CFO will review the month and year noted by the Staff Accountant prior to entry into accounts payable.
U.S. Department of Housing and Urban Development
Continuum of Care – Assistance #14.267 #2023-007 – Major Federal Award Finding
Nature of Finding: Significant Deficiency in Internal Controls over Compliance
Criteria/Condition: The U.S. Department of Housing and Urban Development (HUD) conducted a monitoring assessment of the Continuum of Care Program during the year ended September 30, 2023 in order to assess the Organization’s performance and compliance with applicable federal program requirements. There were various findings noted within the monitoring report. The Organization has addressed most of the findings, but some of the findings remain open.
Cause/Context: The Organization’s responses to the findings included within the HUD monitoring report were not provided in a timely manner, and various findings were not closed timely.
Effect: Continued delay in response to findings could result in disciplinary action from HUD, including reduction or elimination of financial assistance.
Recommendation: We recommend that all open items from the 2023 HUD monitoring report be closed by the Organization. We also recommend that the Organization respond timely to HUD to clear any findings resulting from the upcoming monitoring assessment.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will address any open items from the 2023 HUD monitoring assessment and close any findings. Future findings, if any, will be closed with HUD within 30 days of receipt of the findings.
U.S. Department of Housing and Urban Development
Continuum of Care – Assistance #14.267
#2023-005 – Major Federal Award Finding – Special Tests and Provisions
Nature of Finding: Compliance Finding Special Tests and Provisions and Significant Deficiency in Internal Controls over Compliance
This is a repeat of prior year finding #2022-005.
Criteria/Condition: Per 24 CFR 578.49, rent paid must be reasonable in relation to rents being charged in the area for comparable space. The Organization did not have controls in place to verify that rent paid is reasonable in relation to rents being charged in the area for comparable space.
Cause/Context: Controls were not in place to ensure rent reasonableness. For the rent payments tested, we noted that management's conclusions for rent reasonableness was not documented.
Effect: A lack of controls could result in questioned costs and an inappropriate amount of rent payments being charged to the federal program.
Recommendation: We recommend management establish procedures and controls to require that evidence of review for rent reasonableness be maintained, and that the related conclusions are documented.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
For each client in the HEAL program, where the Organization pays rent for the client, a rent reasonableness form will be completed by the HEAL program staff and approved by the HEAL Program Director and Senior Director. The form will be saved in the client’s file within the Bizstream client management program. The rent reasonableness form will also be submitted to the finance department prior to, or along with, a request for the client’s first rent payment.
U.S. Department of Housing and Urban Development
Continuum of Care – Assistance #14.267
#2023-006 – Major Federal Award Finding - Period of Performance Nature of Finding: Compliance Finding Period of Performance and Material Weakness in Internal Controls over Compliance
Criteria/Condition: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance. The Organization did not have controls in place to verify that costs were being charged to the award in the correct period of performance.
Questioned Costs: $4,035
Identification of How Questioned Costs Were Computed: A sample of 40 non-payroll expenditures totaling approximately $49,000 was selected from a population of approximately $764,000 of non-payroll expenditures. An amount of $263 from an invoice that was selected for testing of non-payroll expenditures charged to the Continuum of Care program was related to the year ending September 30, 2024 and was inappropriately charged to the grant during 2023. Questioned costs are estimated by projecting the error identified in the sample tested to the population of non-payroll expenditures of the Continuum of Care program.
Cause/Context: There are not proper controls in place to review invoices and assign them to the appropriate grant period. One expenditure out of forty non-payroll related expenditures tested for the Continuum of Care grant was for a contracted monthly service that covered multiple performance periods but was billed in its entirety to the current fiscal year.
Effect: An overstatement of expenditures for the Continuum of Care grant was reported in the current year.
Recommendation: We recommend procedures are established to review for proper grant period when recording transactions and creating monthly reimbursement requests.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
1. The Staff Accountant will review the period each expenditure is related to and record the invoice to the appropriate period when entering it into accounts payable. The month and year will be noted on the invoice.
2. The CFO will review the month and year noted by the Staff Accountant prior to entry into accounts payable.
U.S. Department of Housing and Urban Development
Continuum of Care – Assistance #14.267 #2023-007 – Major Federal Award Finding
Nature of Finding: Significant Deficiency in Internal Controls over Compliance
Criteria/Condition: The U.S. Department of Housing and Urban Development (HUD) conducted a monitoring assessment of the Continuum of Care Program during the year ended September 30, 2023 in order to assess the Organization’s performance and compliance with applicable federal program requirements. There were various findings noted within the monitoring report. The Organization has addressed most of the findings, but some of the findings remain open.
Cause/Context: The Organization’s responses to the findings included within the HUD monitoring report were not provided in a timely manner, and various findings were not closed timely.
Effect: Continued delay in response to findings could result in disciplinary action from HUD, including reduction or elimination of financial assistance.
Recommendation: We recommend that all open items from the 2023 HUD monitoring report be closed by the Organization. We also recommend that the Organization respond timely to HUD to clear any findings resulting from the upcoming monitoring assessment.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will address any open items from the 2023 HUD monitoring assessment and close any findings. Future findings, if any, will be closed with HUD within 30 days of receipt of the findings.
U.S. Department of Housing and Urban Development
Continuum of Care – Assistance #14.267
#2023-005 – Major Federal Award Finding – Special Tests and Provisions
Nature of Finding: Compliance Finding Special Tests and Provisions and Significant Deficiency in Internal Controls over Compliance
This is a repeat of prior year finding #2022-005.
Criteria/Condition: Per 24 CFR 578.49, rent paid must be reasonable in relation to rents being charged in the area for comparable space. The Organization did not have controls in place to verify that rent paid is reasonable in relation to rents being charged in the area for comparable space.
Cause/Context: Controls were not in place to ensure rent reasonableness. For the rent payments tested, we noted that management's conclusions for rent reasonableness was not documented.
Effect: A lack of controls could result in questioned costs and an inappropriate amount of rent payments being charged to the federal program.
Recommendation: We recommend management establish procedures and controls to require that evidence of review for rent reasonableness be maintained, and that the related conclusions are documented.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
For each client in the HEAL program, where the Organization pays rent for the client, a rent reasonableness form will be completed by the HEAL program staff and approved by the HEAL Program Director and Senior Director. The form will be saved in the client’s file within the Bizstream client management program. The rent reasonableness form will also be submitted to the finance department prior to, or along with, a request for the client’s first rent payment.
U.S. Department of Housing and Urban Development
Continuum of Care – Assistance #14.267
#2023-006 – Major Federal Award Finding - Period of Performance Nature of Finding: Compliance Finding Period of Performance and Material Weakness in Internal Controls over Compliance
Criteria/Condition: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance. The Organization did not have controls in place to verify that costs were being charged to the award in the correct period of performance.
Questioned Costs: $4,035
Identification of How Questioned Costs Were Computed: A sample of 40 non-payroll expenditures totaling approximately $49,000 was selected from a population of approximately $764,000 of non-payroll expenditures. An amount of $263 from an invoice that was selected for testing of non-payroll expenditures charged to the Continuum of Care program was related to the year ending September 30, 2024 and was inappropriately charged to the grant during 2023. Questioned costs are estimated by projecting the error identified in the sample tested to the population of non-payroll expenditures of the Continuum of Care program.
Cause/Context: There are not proper controls in place to review invoices and assign them to the appropriate grant period. One expenditure out of forty non-payroll related expenditures tested for the Continuum of Care grant was for a contracted monthly service that covered multiple performance periods but was billed in its entirety to the current fiscal year.
Effect: An overstatement of expenditures for the Continuum of Care grant was reported in the current year.
Recommendation: We recommend procedures are established to review for proper grant period when recording transactions and creating monthly reimbursement requests.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
1. The Staff Accountant will review the period each expenditure is related to and record the invoice to the appropriate period when entering it into accounts payable. The month and year will be noted on the invoice.
2. The CFO will review the month and year noted by the Staff Accountant prior to entry into accounts payable.
U.S. Department of Housing and Urban Development
Continuum of Care – Assistance #14.267 #2023-007 – Major Federal Award Finding
Nature of Finding: Significant Deficiency in Internal Controls over Compliance
Criteria/Condition: The U.S. Department of Housing and Urban Development (HUD) conducted a monitoring assessment of the Continuum of Care Program during the year ended September 30, 2023 in order to assess the Organization’s performance and compliance with applicable federal program requirements. There were various findings noted within the monitoring report. The Organization has addressed most of the findings, but some of the findings remain open.
Cause/Context: The Organization’s responses to the findings included within the HUD monitoring report were not provided in a timely manner, and various findings were not closed timely.
Effect: Continued delay in response to findings could result in disciplinary action from HUD, including reduction or elimination of financial assistance.
Recommendation: We recommend that all open items from the 2023 HUD monitoring report be closed by the Organization. We also recommend that the Organization respond timely to HUD to clear any findings resulting from the upcoming monitoring assessment.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will address any open items from the 2023 HUD monitoring assessment and close any findings. Future findings, if any, will be closed with HUD within 30 days of receipt of the findings.
U.S. Department of Housing and Urban Development
Continuum of Care – Assistance #14.267
#2023-005 – Major Federal Award Finding – Special Tests and Provisions
Nature of Finding: Compliance Finding Special Tests and Provisions and Significant Deficiency in Internal Controls over Compliance
This is a repeat of prior year finding #2022-005.
Criteria/Condition: Per 24 CFR 578.49, rent paid must be reasonable in relation to rents being charged in the area for comparable space. The Organization did not have controls in place to verify that rent paid is reasonable in relation to rents being charged in the area for comparable space.
Cause/Context: Controls were not in place to ensure rent reasonableness. For the rent payments tested, we noted that management's conclusions for rent reasonableness was not documented.
Effect: A lack of controls could result in questioned costs and an inappropriate amount of rent payments being charged to the federal program.
Recommendation: We recommend management establish procedures and controls to require that evidence of review for rent reasonableness be maintained, and that the related conclusions are documented.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
For each client in the HEAL program, where the Organization pays rent for the client, a rent reasonableness form will be completed by the HEAL program staff and approved by the HEAL Program Director and Senior Director. The form will be saved in the client’s file within the Bizstream client management program. The rent reasonableness form will also be submitted to the finance department prior to, or along with, a request for the client’s first rent payment.
U.S. Department of Housing and Urban Development
Continuum of Care – Assistance #14.267
#2023-006 – Major Federal Award Finding - Period of Performance Nature of Finding: Compliance Finding Period of Performance and Material Weakness in Internal Controls over Compliance
Criteria/Condition: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance. The Organization did not have controls in place to verify that costs were being charged to the award in the correct period of performance.
Questioned Costs: $4,035
Identification of How Questioned Costs Were Computed: A sample of 40 non-payroll expenditures totaling approximately $49,000 was selected from a population of approximately $764,000 of non-payroll expenditures. An amount of $263 from an invoice that was selected for testing of non-payroll expenditures charged to the Continuum of Care program was related to the year ending September 30, 2024 and was inappropriately charged to the grant during 2023. Questioned costs are estimated by projecting the error identified in the sample tested to the population of non-payroll expenditures of the Continuum of Care program.
Cause/Context: There are not proper controls in place to review invoices and assign them to the appropriate grant period. One expenditure out of forty non-payroll related expenditures tested for the Continuum of Care grant was for a contracted monthly service that covered multiple performance periods but was billed in its entirety to the current fiscal year.
Effect: An overstatement of expenditures for the Continuum of Care grant was reported in the current year.
Recommendation: We recommend procedures are established to review for proper grant period when recording transactions and creating monthly reimbursement requests.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
1. The Staff Accountant will review the period each expenditure is related to and record the invoice to the appropriate period when entering it into accounts payable. The month and year will be noted on the invoice.
2. The CFO will review the month and year noted by the Staff Accountant prior to entry into accounts payable.
U.S. Department of Housing and Urban Development
Continuum of Care – Assistance #14.267 #2023-007 – Major Federal Award Finding
Nature of Finding: Significant Deficiency in Internal Controls over Compliance
Criteria/Condition: The U.S. Department of Housing and Urban Development (HUD) conducted a monitoring assessment of the Continuum of Care Program during the year ended September 30, 2023 in order to assess the Organization’s performance and compliance with applicable federal program requirements. There were various findings noted within the monitoring report. The Organization has addressed most of the findings, but some of the findings remain open.
Cause/Context: The Organization’s responses to the findings included within the HUD monitoring report were not provided in a timely manner, and various findings were not closed timely.
Effect: Continued delay in response to findings could result in disciplinary action from HUD, including reduction or elimination of financial assistance.
Recommendation: We recommend that all open items from the 2023 HUD monitoring report be closed by the Organization. We also recommend that the Organization respond timely to HUD to clear any findings resulting from the upcoming monitoring assessment.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will address any open items from the 2023 HUD monitoring assessment and close any findings. Future findings, if any, will be closed with HUD within 30 days of receipt of the findings.
U.S. Department of Homeland Security, U.S. Department of Justice, and U.S. Department of Health and Human Services
#2023-011 – Major Federal Award Finding
Nature of Finding: Significant Deficiency in Internal Controls over Compliance
This is a repeat of prior year finding #2022-007.
Criteria/Condition: Per 2 CFR 200.510(b), the auditee must prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee's financial statements, which must include the total federal awards expended, as determined in accordance with §200.502. For SEFA reporting, federal expenditures were not disclosed for one program and were overstated or understated for other programs.
Cause/Context: Expenditures for the Emergency Food and Shelter National Board Program were excluded from the client-prepared SEFA. There were various other grants with allocations between state and federal funding that were not presented properly on the SEFA. The SEFA presented has been adjusted for these errors.
Effect: Controls in place did not sufficiently ensure the completeness and accuracy of the SEFA.
Recommendation: We recommend the Organization enhance its procedures and controls to ensure data accumulated to prepare the SEFA is complete and accurate.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
The Schedule of Expenditures of Federal Awards (SEFA) will be reviewed for accuracy by either the CFO or CEO after it is produced, to ensure that all federal awards are included, and that the amounts on the schedule are accurate.
U.S. Department of Homeland Security, U.S. Department of Justice, and U.S. Department of Health and Human Services
#2023-011 – Major Federal Award Finding
Nature of Finding: Significant Deficiency in Internal Controls over Compliance
This is a repeat of prior year finding #2022-007.
Criteria/Condition: Per 2 CFR 200.510(b), the auditee must prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee's financial statements, which must include the total federal awards expended, as determined in accordance with §200.502. For SEFA reporting, federal expenditures were not disclosed for one program and were overstated or understated for other programs.
Cause/Context: Expenditures for the Emergency Food and Shelter National Board Program were excluded from the client-prepared SEFA. There were various other grants with allocations between state and federal funding that were not presented properly on the SEFA. The SEFA presented has been adjusted for these errors.
Effect: Controls in place did not sufficiently ensure the completeness and accuracy of the SEFA.
Recommendation: We recommend the Organization enhance its procedures and controls to ensure data accumulated to prepare the SEFA is complete and accurate.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
The Schedule of Expenditures of Federal Awards (SEFA) will be reviewed for accuracy by either the CFO or CEO after it is produced, to ensure that all federal awards are included, and that the amounts on the schedule are accurate.
U.S. Department of Homeland Security, U.S. Department of Justice, and U.S. Department of Health and Human Services
#2023-011 – Major Federal Award Finding
Nature of Finding: Significant Deficiency in Internal Controls over Compliance
This is a repeat of prior year finding #2022-007.
Criteria/Condition: Per 2 CFR 200.510(b), the auditee must prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee's financial statements, which must include the total federal awards expended, as determined in accordance with §200.502. For SEFA reporting, federal expenditures were not disclosed for one program and were overstated or understated for other programs.
Cause/Context: Expenditures for the Emergency Food and Shelter National Board Program were excluded from the client-prepared SEFA. There were various other grants with allocations between state and federal funding that were not presented properly on the SEFA. The SEFA presented has been adjusted for these errors.
Effect: Controls in place did not sufficiently ensure the completeness and accuracy of the SEFA.
Recommendation: We recommend the Organization enhance its procedures and controls to ensure data accumulated to prepare the SEFA is complete and accurate.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
The Schedule of Expenditures of Federal Awards (SEFA) will be reviewed for accuracy by either the CFO or CEO after it is produced, to ensure that all federal awards are included, and that the amounts on the schedule are accurate.
U.S. Department of Justice
Crime Victim Assistance – Assistance #16.575
#2023-008 – Major Federal Award Finding – Reporting
Nature of Finding: Compliance Finding Reporting and Material Weakness in Internal Controls over Compliance
This is a repeat of prior year finding #2022-006.
Criteria/Condition: Federal regulations 2 CFR 200.328 - 200.329 provide that required reporting under the federal program must be completed timely and accurately. The federal award agreement includes specific report filing due dates. Segregation of duties is also a key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction or process from beginning to end. We noted during testing of sixteen different required reports that five of these reports tested were not filed in a timely manner. There were also no review procedures in place surrounding these reports.
Cause/Context: Controls were not in place to ensure timely reporting. Only one individual was involved in the reporting process for the reports. A total of five of the reports tested were submitted more than ten days late.
Effect: A lack of controls could result in late or failed reporting.
Recommendation: We recommend the Organization establish procedures and controls to ensure financial and performance reports are filed timely.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will ensure that all federal award reports are filed in a timely manner. The Organization is in the process of posting a new position, Director of Grants and Compliance. The individual in this new role will be responsible for tracking report due dates and working with the individuals responsible for the content of these reports to ensure the information is accurate and on time. In situations where the Director of Grants and Compliance is responsible for gathering the data for required reporting, the data will be reviewed by either the CFO or CEO prior to submission of the report.
U.S. Department of Justice
Crime Victim Assistance – Assistance #16.575
#2023-009 – Major Federal Award Finding – Cash Management
Nature of Finding: Compliance Finding Cash Management and Significant Deficiency in Internal Controls over Compliance
Criteria/Condition: 2 CFR 200.305 requires that non-federal entities must minimize the time elapsing between the transfer of federal funds to the non-federal entity and the subsequent disbursement of the funds by the non-federal entity for program costs. The Organization did not have proper controls in place to verify that specific vendor invoices were paid within a reasonable amount of time of requesting reimbursement for the expenditures.
Questioned Costs: $2,381
Identification of How Questioned Costs Were Computed: The issues of noncompliance related to cash management was limited to one vendor that was not paid within a reasonable amount of time of being reimbursed for the costs. This was determined to be an isolated incident. Questioned costs include the two invoices that were charged to the grant for this vendor during the year ended September 30, 2023 and were not paid to the vendor within a reasonable amount of time of being reimbursed for the expenditures.
Cause/Context: Controls were not in place to ensure expenditures were paid to the vendor prior to requesting reimbursements. This circumstance was determined to be an isolated incident due to the unique nature of the vendor invoices. The Organization was withholding payment to the vendor until it determined that both invoices were proper.
Effect: The lack of controls could result in requests for reimbursement being submitted for unpaid expenditures.
Recommendation: We recommend the Organization establish procedures and incorporate controls to review that expenditures are paid prior to submitting requests for reimbursement.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
Each month, an aged open accounts payable report will be produced as part of the month end closing. Invoices that are past due will be paid in the following batch of payments (which are typically run weekly). If it is determined that the invoice is not being paid for a valid reason, it will be removed from accounts payable at that time.
U.S. Department of Justice
Crime Victim Assistance – Assistance #16.575
#2023-009 – Major Federal Award Finding – Cash Management
Nature of Finding: Compliance Finding Cash Management and Significant Deficiency in Internal Controls over Compliance
Criteria/Condition: 2 CFR 200.305 requires that non-federal entities must minimize the time elapsing between the transfer of federal funds to the non-federal entity and the subsequent disbursement of the funds by the non-federal entity for program costs. The Organization did not have proper controls in place to verify that specific vendor invoices were paid within a reasonable amount of time of requesting reimbursement for the expenditures.
Questioned Costs: $2,381
Identification of How Questioned Costs Were Computed: The issues of noncompliance related to cash management was limited to one vendor that was not paid within a reasonable amount of time of being reimbursed for the costs. This was determined to be an isolated incident. Questioned costs include the two invoices that were charged to the grant for this vendor during the year ended September 30, 2023 and were not paid to the vendor within a reasonable amount of time of being reimbursed for the expenditures.
Cause/Context: Controls were not in place to ensure expenditures were paid to the vendor prior to requesting reimbursements. This circumstance was determined to be an isolated incident due to the unique nature of the vendor invoices. The Organization was withholding payment to the vendor until it determined that both invoices were proper.
Effect: The lack of controls could result in requests for reimbursement being submitted for unpaid expenditures.
Recommendation: We recommend the Organization establish procedures and incorporate controls to review that expenditures are paid prior to submitting requests for reimbursement.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
Each month, an aged open accounts payable report will be produced as part of the month end closing. Invoices that are past due will be paid in the following batch of payments (which are typically run weekly). If it is determined that the invoice is not being paid for a valid reason, it will be removed from accounts payable at that time.
#2023-010 – Major Federal Award Finding – Period of Performance
Nature of Finding: Compliance Finding Period of Performance and Material Weakness in Internal Controls over Compliance
Criteria/Condition: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance. The Organization did not have controls in place to verify that costs were being charged to the award in the correct period of performance.
Questioned Costs: $20,790
Identification of How Questioned Costs Were Computed: A sample of 40 non-payroll expenditures totaling approximately $48,000 was selected from a population of approximately $552,000 of non-payroll expenditures. An amount of $1,817 combined from two invoices that were charged to the Crime Victim Assistance program was related to the year ending September 30, 2024 and was inappropriately charged to the grant during 2023. Questioned costs are estimated by projecting the error identified in the sample tested to the population of non-payroll expenditures of the Crime Victim Assistance program.
Cause/Context: There are not proper controls in place to review invoices and assign them to the appropriate grant period. Two expenditures out of forty non-payroll related expenditures tested for the Crime Victim Assistance grant was for a contracted annual service that covered multiple performance periods but was billed in its entirety to the current fiscal year.
Effect: An overstatement of expenditures for the Crime Victim Assistance grant was reported in the current year.
Recommendation: We recommend procedures are established to review for proper grant period when recording transactions and creating monthly reimbursement requests.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures.
1. The Staff Accountant will review the period each expenditure is related to and record the invoice to the appropriate period when entering it into accounts payable. The month and year will be noted on the invoice.
2. The CFO will review the month and year noted by the Staff Accountant prior to entry into accounts payable.
U.S. Department of Homeland Security, U.S. Department of Justice, and U.S. Department of Health and Human Services
#2023-011 – Major Federal Award Finding
Nature of Finding: Significant Deficiency in Internal Controls over Compliance
This is a repeat of prior year finding #2022-007.
Criteria/Condition: Per 2 CFR 200.510(b), the auditee must prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee's financial statements, which must include the total federal awards expended, as determined in accordance with §200.502. For SEFA reporting, federal expenditures were not disclosed for one program and were overstated or understated for other programs.
Cause/Context: Expenditures for the Emergency Food and Shelter National Board Program were excluded from the client-prepared SEFA. There were various other grants with allocations between state and federal funding that were not presented properly on the SEFA. The SEFA presented has been adjusted for these errors.
Effect: Controls in place did not sufficiently ensure the completeness and accuracy of the SEFA.
Recommendation: We recommend the Organization enhance its procedures and controls to ensure data accumulated to prepare the SEFA is complete and accurate.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
The Schedule of Expenditures of Federal Awards (SEFA) will be reviewed for accuracy by either the CFO or CEO after it is produced, to ensure that all federal awards are included, and that the amounts on the schedule are accurate.
U.S. Department of Justice
Crime Victim Assistance – Assistance #16.575
#2023-008 – Major Federal Award Finding – Reporting
Nature of Finding: Compliance Finding Reporting and Material Weakness in Internal Controls over Compliance
This is a repeat of prior year finding #2022-006.
Criteria/Condition: Federal regulations 2 CFR 200.328 - 200.329 provide that required reporting under the federal program must be completed timely and accurately. The federal award agreement includes specific report filing due dates. Segregation of duties is also a key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction or process from beginning to end. We noted during testing of sixteen different required reports that five of these reports tested were not filed in a timely manner. There were also no review procedures in place surrounding these reports.
Cause/Context: Controls were not in place to ensure timely reporting. Only one individual was involved in the reporting process for the reports. A total of five of the reports tested were submitted more than ten days late.
Effect: A lack of controls could result in late or failed reporting.
Recommendation: We recommend the Organization establish procedures and controls to ensure financial and performance reports are filed timely.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will ensure that all federal award reports are filed in a timely manner. The Organization is in the process of posting a new position, Director of Grants and Compliance. The individual in this new role will be responsible for tracking report due dates and working with the individuals responsible for the content of these reports to ensure the information is accurate and on time. In situations where the Director of Grants and Compliance is responsible for gathering the data for required reporting, the data will be reviewed by either the CFO or CEO prior to submission of the report.
U.S. Department of Justice
Crime Victim Assistance – Assistance #16.575
#2023-009 – Major Federal Award Finding – Cash Management
Nature of Finding: Compliance Finding Cash Management and Significant Deficiency in Internal Controls over Compliance
Criteria/Condition: 2 CFR 200.305 requires that non-federal entities must minimize the time elapsing between the transfer of federal funds to the non-federal entity and the subsequent disbursement of the funds by the non-federal entity for program costs. The Organization did not have proper controls in place to verify that specific vendor invoices were paid within a reasonable amount of time of requesting reimbursement for the expenditures.
Questioned Costs: $2,381
Identification of How Questioned Costs Were Computed: The issues of noncompliance related to cash management was limited to one vendor that was not paid within a reasonable amount of time of being reimbursed for the costs. This was determined to be an isolated incident. Questioned costs include the two invoices that were charged to the grant for this vendor during the year ended September 30, 2023 and were not paid to the vendor within a reasonable amount of time of being reimbursed for the expenditures.
Cause/Context: Controls were not in place to ensure expenditures were paid to the vendor prior to requesting reimbursements. This circumstance was determined to be an isolated incident due to the unique nature of the vendor invoices. The Organization was withholding payment to the vendor until it determined that both invoices were proper.
Effect: The lack of controls could result in requests for reimbursement being submitted for unpaid expenditures.
Recommendation: We recommend the Organization establish procedures and incorporate controls to review that expenditures are paid prior to submitting requests for reimbursement.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
Each month, an aged open accounts payable report will be produced as part of the month end closing. Invoices that are past due will be paid in the following batch of payments (which are typically run weekly). If it is determined that the invoice is not being paid for a valid reason, it will be removed from accounts payable at that time.
U.S. Department of Justice
Crime Victim Assistance – Assistance #16.575
#2023-009 – Major Federal Award Finding – Cash Management
Nature of Finding: Compliance Finding Cash Management and Significant Deficiency in Internal Controls over Compliance
Criteria/Condition: 2 CFR 200.305 requires that non-federal entities must minimize the time elapsing between the transfer of federal funds to the non-federal entity and the subsequent disbursement of the funds by the non-federal entity for program costs. The Organization did not have proper controls in place to verify that specific vendor invoices were paid within a reasonable amount of time of requesting reimbursement for the expenditures.
Questioned Costs: $2,381
Identification of How Questioned Costs Were Computed: The issues of noncompliance related to cash management was limited to one vendor that was not paid within a reasonable amount of time of being reimbursed for the costs. This was determined to be an isolated incident. Questioned costs include the two invoices that were charged to the grant for this vendor during the year ended September 30, 2023 and were not paid to the vendor within a reasonable amount of time of being reimbursed for the expenditures.
Cause/Context: Controls were not in place to ensure expenditures were paid to the vendor prior to requesting reimbursements. This circumstance was determined to be an isolated incident due to the unique nature of the vendor invoices. The Organization was withholding payment to the vendor until it determined that both invoices were proper.
Effect: The lack of controls could result in requests for reimbursement being submitted for unpaid expenditures.
Recommendation: We recommend the Organization establish procedures and incorporate controls to review that expenditures are paid prior to submitting requests for reimbursement.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
Each month, an aged open accounts payable report will be produced as part of the month end closing. Invoices that are past due will be paid in the following batch of payments (which are typically run weekly). If it is determined that the invoice is not being paid for a valid reason, it will be removed from accounts payable at that time.
#2023-010 – Major Federal Award Finding – Period of Performance
Nature of Finding: Compliance Finding Period of Performance and Material Weakness in Internal Controls over Compliance
Criteria/Condition: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance. The Organization did not have controls in place to verify that costs were being charged to the award in the correct period of performance.
Questioned Costs: $20,790
Identification of How Questioned Costs Were Computed: A sample of 40 non-payroll expenditures totaling approximately $48,000 was selected from a population of approximately $552,000 of non-payroll expenditures. An amount of $1,817 combined from two invoices that were charged to the Crime Victim Assistance program was related to the year ending September 30, 2024 and was inappropriately charged to the grant during 2023. Questioned costs are estimated by projecting the error identified in the sample tested to the population of non-payroll expenditures of the Crime Victim Assistance program.
Cause/Context: There are not proper controls in place to review invoices and assign them to the appropriate grant period. Two expenditures out of forty non-payroll related expenditures tested for the Crime Victim Assistance grant was for a contracted annual service that covered multiple performance periods but was billed in its entirety to the current fiscal year.
Effect: An overstatement of expenditures for the Crime Victim Assistance grant was reported in the current year.
Recommendation: We recommend procedures are established to review for proper grant period when recording transactions and creating monthly reimbursement requests.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures.
1. The Staff Accountant will review the period each expenditure is related to and record the invoice to the appropriate period when entering it into accounts payable. The month and year will be noted on the invoice.
2. The CFO will review the month and year noted by the Staff Accountant prior to entry into accounts payable.
U.S. Department of Homeland Security, U.S. Department of Justice, and U.S. Department of Health and Human Services
#2023-011 – Major Federal Award Finding
Nature of Finding: Significant Deficiency in Internal Controls over Compliance
This is a repeat of prior year finding #2022-007.
Criteria/Condition: Per 2 CFR 200.510(b), the auditee must prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee's financial statements, which must include the total federal awards expended, as determined in accordance with §200.502. For SEFA reporting, federal expenditures were not disclosed for one program and were overstated or understated for other programs.
Cause/Context: Expenditures for the Emergency Food and Shelter National Board Program were excluded from the client-prepared SEFA. There were various other grants with allocations between state and federal funding that were not presented properly on the SEFA. The SEFA presented has been adjusted for these errors.
Effect: Controls in place did not sufficiently ensure the completeness and accuracy of the SEFA.
Recommendation: We recommend the Organization enhance its procedures and controls to ensure data accumulated to prepare the SEFA is complete and accurate.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
The Schedule of Expenditures of Federal Awards (SEFA) will be reviewed for accuracy by either the CFO or CEO after it is produced, to ensure that all federal awards are included, and that the amounts on the schedule are accurate.
U.S. Department of Justice
Crime Victim Assistance – Assistance #16.575
#2023-008 – Major Federal Award Finding – Reporting
Nature of Finding: Compliance Finding Reporting and Material Weakness in Internal Controls over Compliance
This is a repeat of prior year finding #2022-006.
Criteria/Condition: Federal regulations 2 CFR 200.328 - 200.329 provide that required reporting under the federal program must be completed timely and accurately. The federal award agreement includes specific report filing due dates. Segregation of duties is also a key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction or process from beginning to end. We noted during testing of sixteen different required reports that five of these reports tested were not filed in a timely manner. There were also no review procedures in place surrounding these reports.
Cause/Context: Controls were not in place to ensure timely reporting. Only one individual was involved in the reporting process for the reports. A total of five of the reports tested were submitted more than ten days late.
Effect: A lack of controls could result in late or failed reporting.
Recommendation: We recommend the Organization establish procedures and controls to ensure financial and performance reports are filed timely.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will ensure that all federal award reports are filed in a timely manner. The Organization is in the process of posting a new position, Director of Grants and Compliance. The individual in this new role will be responsible for tracking report due dates and working with the individuals responsible for the content of these reports to ensure the information is accurate and on time. In situations where the Director of Grants and Compliance is responsible for gathering the data for required reporting, the data will be reviewed by either the CFO or CEO prior to submission of the report.
U.S. Department of Justice
Crime Victim Assistance – Assistance #16.575
#2023-009 – Major Federal Award Finding – Cash Management
Nature of Finding: Compliance Finding Cash Management and Significant Deficiency in Internal Controls over Compliance
Criteria/Condition: 2 CFR 200.305 requires that non-federal entities must minimize the time elapsing between the transfer of federal funds to the non-federal entity and the subsequent disbursement of the funds by the non-federal entity for program costs. The Organization did not have proper controls in place to verify that specific vendor invoices were paid within a reasonable amount of time of requesting reimbursement for the expenditures.
Questioned Costs: $2,381
Identification of How Questioned Costs Were Computed: The issues of noncompliance related to cash management was limited to one vendor that was not paid within a reasonable amount of time of being reimbursed for the costs. This was determined to be an isolated incident. Questioned costs include the two invoices that were charged to the grant for this vendor during the year ended September 30, 2023 and were not paid to the vendor within a reasonable amount of time of being reimbursed for the expenditures.
Cause/Context: Controls were not in place to ensure expenditures were paid to the vendor prior to requesting reimbursements. This circumstance was determined to be an isolated incident due to the unique nature of the vendor invoices. The Organization was withholding payment to the vendor until it determined that both invoices were proper.
Effect: The lack of controls could result in requests for reimbursement being submitted for unpaid expenditures.
Recommendation: We recommend the Organization establish procedures and incorporate controls to review that expenditures are paid prior to submitting requests for reimbursement.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
Each month, an aged open accounts payable report will be produced as part of the month end closing. Invoices that are past due will be paid in the following batch of payments (which are typically run weekly). If it is determined that the invoice is not being paid for a valid reason, it will be removed from accounts payable at that time.
U.S. Department of Justice
Crime Victim Assistance – Assistance #16.575
#2023-009 – Major Federal Award Finding – Cash Management
Nature of Finding: Compliance Finding Cash Management and Significant Deficiency in Internal Controls over Compliance
Criteria/Condition: 2 CFR 200.305 requires that non-federal entities must minimize the time elapsing between the transfer of federal funds to the non-federal entity and the subsequent disbursement of the funds by the non-federal entity for program costs. The Organization did not have proper controls in place to verify that specific vendor invoices were paid within a reasonable amount of time of requesting reimbursement for the expenditures.
Questioned Costs: $2,381
Identification of How Questioned Costs Were Computed: The issues of noncompliance related to cash management was limited to one vendor that was not paid within a reasonable amount of time of being reimbursed for the costs. This was determined to be an isolated incident. Questioned costs include the two invoices that were charged to the grant for this vendor during the year ended September 30, 2023 and were not paid to the vendor within a reasonable amount of time of being reimbursed for the expenditures.
Cause/Context: Controls were not in place to ensure expenditures were paid to the vendor prior to requesting reimbursements. This circumstance was determined to be an isolated incident due to the unique nature of the vendor invoices. The Organization was withholding payment to the vendor until it determined that both invoices were proper.
Effect: The lack of controls could result in requests for reimbursement being submitted for unpaid expenditures.
Recommendation: We recommend the Organization establish procedures and incorporate controls to review that expenditures are paid prior to submitting requests for reimbursement.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
Each month, an aged open accounts payable report will be produced as part of the month end closing. Invoices that are past due will be paid in the following batch of payments (which are typically run weekly). If it is determined that the invoice is not being paid for a valid reason, it will be removed from accounts payable at that time.
#2023-010 – Major Federal Award Finding – Period of Performance
Nature of Finding: Compliance Finding Period of Performance and Material Weakness in Internal Controls over Compliance
Criteria/Condition: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance. The Organization did not have controls in place to verify that costs were being charged to the award in the correct period of performance.
Questioned Costs: $20,790
Identification of How Questioned Costs Were Computed: A sample of 40 non-payroll expenditures totaling approximately $48,000 was selected from a population of approximately $552,000 of non-payroll expenditures. An amount of $1,817 combined from two invoices that were charged to the Crime Victim Assistance program was related to the year ending September 30, 2024 and was inappropriately charged to the grant during 2023. Questioned costs are estimated by projecting the error identified in the sample tested to the population of non-payroll expenditures of the Crime Victim Assistance program.
Cause/Context: There are not proper controls in place to review invoices and assign them to the appropriate grant period. Two expenditures out of forty non-payroll related expenditures tested for the Crime Victim Assistance grant was for a contracted annual service that covered multiple performance periods but was billed in its entirety to the current fiscal year.
Effect: An overstatement of expenditures for the Crime Victim Assistance grant was reported in the current year.
Recommendation: We recommend procedures are established to review for proper grant period when recording transactions and creating monthly reimbursement requests.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures.
1. The Staff Accountant will review the period each expenditure is related to and record the invoice to the appropriate period when entering it into accounts payable. The month and year will be noted on the invoice.
2. The CFO will review the month and year noted by the Staff Accountant prior to entry into accounts payable.
U.S. Department of Homeland Security, U.S. Department of Justice, and U.S. Department of Health and Human Services
#2023-011 – Major Federal Award Finding
Nature of Finding: Significant Deficiency in Internal Controls over Compliance
This is a repeat of prior year finding #2022-007.
Criteria/Condition: Per 2 CFR 200.510(b), the auditee must prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee's financial statements, which must include the total federal awards expended, as determined in accordance with §200.502. For SEFA reporting, federal expenditures were not disclosed for one program and were overstated or understated for other programs.
Cause/Context: Expenditures for the Emergency Food and Shelter National Board Program were excluded from the client-prepared SEFA. There were various other grants with allocations between state and federal funding that were not presented properly on the SEFA. The SEFA presented has been adjusted for these errors.
Effect: Controls in place did not sufficiently ensure the completeness and accuracy of the SEFA.
Recommendation: We recommend the Organization enhance its procedures and controls to ensure data accumulated to prepare the SEFA is complete and accurate.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
The Schedule of Expenditures of Federal Awards (SEFA) will be reviewed for accuracy by either the CFO or CEO after it is produced, to ensure that all federal awards are included, and that the amounts on the schedule are accurate.
U.S. Department of Justice
Crime Victim Assistance – Assistance #16.575
#2023-008 – Major Federal Award Finding – Reporting
Nature of Finding: Compliance Finding Reporting and Material Weakness in Internal Controls over Compliance
This is a repeat of prior year finding #2022-006.
Criteria/Condition: Federal regulations 2 CFR 200.328 - 200.329 provide that required reporting under the federal program must be completed timely and accurately. The federal award agreement includes specific report filing due dates. Segregation of duties is also a key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction or process from beginning to end. We noted during testing of sixteen different required reports that five of these reports tested were not filed in a timely manner. There were also no review procedures in place surrounding these reports.
Cause/Context: Controls were not in place to ensure timely reporting. Only one individual was involved in the reporting process for the reports. A total of five of the reports tested were submitted more than ten days late.
Effect: A lack of controls could result in late or failed reporting.
Recommendation: We recommend the Organization establish procedures and controls to ensure financial and performance reports are filed timely.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will ensure that all federal award reports are filed in a timely manner. The Organization is in the process of posting a new position, Director of Grants and Compliance. The individual in this new role will be responsible for tracking report due dates and working with the individuals responsible for the content of these reports to ensure the information is accurate and on time. In situations where the Director of Grants and Compliance is responsible for gathering the data for required reporting, the data will be reviewed by either the CFO or CEO prior to submission of the report.
U.S. Department of Justice
Crime Victim Assistance – Assistance #16.575
#2023-009 – Major Federal Award Finding – Cash Management
Nature of Finding: Compliance Finding Cash Management and Significant Deficiency in Internal Controls over Compliance
Criteria/Condition: 2 CFR 200.305 requires that non-federal entities must minimize the time elapsing between the transfer of federal funds to the non-federal entity and the subsequent disbursement of the funds by the non-federal entity for program costs. The Organization did not have proper controls in place to verify that specific vendor invoices were paid within a reasonable amount of time of requesting reimbursement for the expenditures.
Questioned Costs: $2,381
Identification of How Questioned Costs Were Computed: The issues of noncompliance related to cash management was limited to one vendor that was not paid within a reasonable amount of time of being reimbursed for the costs. This was determined to be an isolated incident. Questioned costs include the two invoices that were charged to the grant for this vendor during the year ended September 30, 2023 and were not paid to the vendor within a reasonable amount of time of being reimbursed for the expenditures.
Cause/Context: Controls were not in place to ensure expenditures were paid to the vendor prior to requesting reimbursements. This circumstance was determined to be an isolated incident due to the unique nature of the vendor invoices. The Organization was withholding payment to the vendor until it determined that both invoices were proper.
Effect: The lack of controls could result in requests for reimbursement being submitted for unpaid expenditures.
Recommendation: We recommend the Organization establish procedures and incorporate controls to review that expenditures are paid prior to submitting requests for reimbursement.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
Each month, an aged open accounts payable report will be produced as part of the month end closing. Invoices that are past due will be paid in the following batch of payments (which are typically run weekly). If it is determined that the invoice is not being paid for a valid reason, it will be removed from accounts payable at that time.
U.S. Department of Justice
Crime Victim Assistance – Assistance #16.575
#2023-009 – Major Federal Award Finding – Cash Management
Nature of Finding: Compliance Finding Cash Management and Significant Deficiency in Internal Controls over Compliance
Criteria/Condition: 2 CFR 200.305 requires that non-federal entities must minimize the time elapsing between the transfer of federal funds to the non-federal entity and the subsequent disbursement of the funds by the non-federal entity for program costs. The Organization did not have proper controls in place to verify that specific vendor invoices were paid within a reasonable amount of time of requesting reimbursement for the expenditures.
Questioned Costs: $2,381
Identification of How Questioned Costs Were Computed: The issues of noncompliance related to cash management was limited to one vendor that was not paid within a reasonable amount of time of being reimbursed for the costs. This was determined to be an isolated incident. Questioned costs include the two invoices that were charged to the grant for this vendor during the year ended September 30, 2023 and were not paid to the vendor within a reasonable amount of time of being reimbursed for the expenditures.
Cause/Context: Controls were not in place to ensure expenditures were paid to the vendor prior to requesting reimbursements. This circumstance was determined to be an isolated incident due to the unique nature of the vendor invoices. The Organization was withholding payment to the vendor until it determined that both invoices were proper.
Effect: The lack of controls could result in requests for reimbursement being submitted for unpaid expenditures.
Recommendation: We recommend the Organization establish procedures and incorporate controls to review that expenditures are paid prior to submitting requests for reimbursement.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
Each month, an aged open accounts payable report will be produced as part of the month end closing. Invoices that are past due will be paid in the following batch of payments (which are typically run weekly). If it is determined that the invoice is not being paid for a valid reason, it will be removed from accounts payable at that time.
#2023-010 – Major Federal Award Finding – Period of Performance
Nature of Finding: Compliance Finding Period of Performance and Material Weakness in Internal Controls over Compliance
Criteria/Condition: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance. The Organization did not have controls in place to verify that costs were being charged to the award in the correct period of performance.
Questioned Costs: $20,790
Identification of How Questioned Costs Were Computed: A sample of 40 non-payroll expenditures totaling approximately $48,000 was selected from a population of approximately $552,000 of non-payroll expenditures. An amount of $1,817 combined from two invoices that were charged to the Crime Victim Assistance program was related to the year ending September 30, 2024 and was inappropriately charged to the grant during 2023. Questioned costs are estimated by projecting the error identified in the sample tested to the population of non-payroll expenditures of the Crime Victim Assistance program.
Cause/Context: There are not proper controls in place to review invoices and assign them to the appropriate grant period. Two expenditures out of forty non-payroll related expenditures tested for the Crime Victim Assistance grant was for a contracted annual service that covered multiple performance periods but was billed in its entirety to the current fiscal year.
Effect: An overstatement of expenditures for the Crime Victim Assistance grant was reported in the current year.
Recommendation: We recommend procedures are established to review for proper grant period when recording transactions and creating monthly reimbursement requests.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures.
1. The Staff Accountant will review the period each expenditure is related to and record the invoice to the appropriate period when entering it into accounts payable. The month and year will be noted on the invoice.
2. The CFO will review the month and year noted by the Staff Accountant prior to entry into accounts payable.
U.S. Department of Homeland Security, U.S. Department of Justice, and U.S. Department of Health and Human Services
#2023-011 – Major Federal Award Finding
Nature of Finding: Significant Deficiency in Internal Controls over Compliance
This is a repeat of prior year finding #2022-007.
Criteria/Condition: Per 2 CFR 200.510(b), the auditee must prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee's financial statements, which must include the total federal awards expended, as determined in accordance with §200.502. For SEFA reporting, federal expenditures were not disclosed for one program and were overstated or understated for other programs.
Cause/Context: Expenditures for the Emergency Food and Shelter National Board Program were excluded from the client-prepared SEFA. There were various other grants with allocations between state and federal funding that were not presented properly on the SEFA. The SEFA presented has been adjusted for these errors.
Effect: Controls in place did not sufficiently ensure the completeness and accuracy of the SEFA.
Recommendation: We recommend the Organization enhance its procedures and controls to ensure data accumulated to prepare the SEFA is complete and accurate.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
The Schedule of Expenditures of Federal Awards (SEFA) will be reviewed for accuracy by either the CFO or CEO after it is produced, to ensure that all federal awards are included, and that the amounts on the schedule are accurate.
U.S. Department of Justice
Crime Victim Assistance – Assistance #16.575
#2023-008 – Major Federal Award Finding – Reporting
Nature of Finding: Compliance Finding Reporting and Material Weakness in Internal Controls over Compliance
This is a repeat of prior year finding #2022-006.
Criteria/Condition: Federal regulations 2 CFR 200.328 - 200.329 provide that required reporting under the federal program must be completed timely and accurately. The federal award agreement includes specific report filing due dates. Segregation of duties is also a key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction or process from beginning to end. We noted during testing of sixteen different required reports that five of these reports tested were not filed in a timely manner. There were also no review procedures in place surrounding these reports.
Cause/Context: Controls were not in place to ensure timely reporting. Only one individual was involved in the reporting process for the reports. A total of five of the reports tested were submitted more than ten days late.
Effect: A lack of controls could result in late or failed reporting.
Recommendation: We recommend the Organization establish procedures and controls to ensure financial and performance reports are filed timely.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will ensure that all federal award reports are filed in a timely manner. The Organization is in the process of posting a new position, Director of Grants and Compliance. The individual in this new role will be responsible for tracking report due dates and working with the individuals responsible for the content of these reports to ensure the information is accurate and on time. In situations where the Director of Grants and Compliance is responsible for gathering the data for required reporting, the data will be reviewed by either the CFO or CEO prior to submission of the report.
U.S. Department of Justice
Crime Victim Assistance – Assistance #16.575
#2023-009 – Major Federal Award Finding – Cash Management
Nature of Finding: Compliance Finding Cash Management and Significant Deficiency in Internal Controls over Compliance
Criteria/Condition: 2 CFR 200.305 requires that non-federal entities must minimize the time elapsing between the transfer of federal funds to the non-federal entity and the subsequent disbursement of the funds by the non-federal entity for program costs. The Organization did not have proper controls in place to verify that specific vendor invoices were paid within a reasonable amount of time of requesting reimbursement for the expenditures.
Questioned Costs: $2,381
Identification of How Questioned Costs Were Computed: The issues of noncompliance related to cash management was limited to one vendor that was not paid within a reasonable amount of time of being reimbursed for the costs. This was determined to be an isolated incident. Questioned costs include the two invoices that were charged to the grant for this vendor during the year ended September 30, 2023 and were not paid to the vendor within a reasonable amount of time of being reimbursed for the expenditures.
Cause/Context: Controls were not in place to ensure expenditures were paid to the vendor prior to requesting reimbursements. This circumstance was determined to be an isolated incident due to the unique nature of the vendor invoices. The Organization was withholding payment to the vendor until it determined that both invoices were proper.
Effect: The lack of controls could result in requests for reimbursement being submitted for unpaid expenditures.
Recommendation: We recommend the Organization establish procedures and incorporate controls to review that expenditures are paid prior to submitting requests for reimbursement.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
Each month, an aged open accounts payable report will be produced as part of the month end closing. Invoices that are past due will be paid in the following batch of payments (which are typically run weekly). If it is determined that the invoice is not being paid for a valid reason, it will be removed from accounts payable at that time.
U.S. Department of Justice
Crime Victim Assistance – Assistance #16.575
#2023-009 – Major Federal Award Finding – Cash Management
Nature of Finding: Compliance Finding Cash Management and Significant Deficiency in Internal Controls over Compliance
Criteria/Condition: 2 CFR 200.305 requires that non-federal entities must minimize the time elapsing between the transfer of federal funds to the non-federal entity and the subsequent disbursement of the funds by the non-federal entity for program costs. The Organization did not have proper controls in place to verify that specific vendor invoices were paid within a reasonable amount of time of requesting reimbursement for the expenditures.
Questioned Costs: $2,381
Identification of How Questioned Costs Were Computed: The issues of noncompliance related to cash management was limited to one vendor that was not paid within a reasonable amount of time of being reimbursed for the costs. This was determined to be an isolated incident. Questioned costs include the two invoices that were charged to the grant for this vendor during the year ended September 30, 2023 and were not paid to the vendor within a reasonable amount of time of being reimbursed for the expenditures.
Cause/Context: Controls were not in place to ensure expenditures were paid to the vendor prior to requesting reimbursements. This circumstance was determined to be an isolated incident due to the unique nature of the vendor invoices. The Organization was withholding payment to the vendor until it determined that both invoices were proper.
Effect: The lack of controls could result in requests for reimbursement being submitted for unpaid expenditures.
Recommendation: We recommend the Organization establish procedures and incorporate controls to review that expenditures are paid prior to submitting requests for reimbursement.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
Each month, an aged open accounts payable report will be produced as part of the month end closing. Invoices that are past due will be paid in the following batch of payments (which are typically run weekly). If it is determined that the invoice is not being paid for a valid reason, it will be removed from accounts payable at that time.
#2023-010 – Major Federal Award Finding – Period of Performance
Nature of Finding: Compliance Finding Period of Performance and Material Weakness in Internal Controls over Compliance
Criteria/Condition: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance. The Organization did not have controls in place to verify that costs were being charged to the award in the correct period of performance.
Questioned Costs: $20,790
Identification of How Questioned Costs Were Computed: A sample of 40 non-payroll expenditures totaling approximately $48,000 was selected from a population of approximately $552,000 of non-payroll expenditures. An amount of $1,817 combined from two invoices that were charged to the Crime Victim Assistance program was related to the year ending September 30, 2024 and was inappropriately charged to the grant during 2023. Questioned costs are estimated by projecting the error identified in the sample tested to the population of non-payroll expenditures of the Crime Victim Assistance program.
Cause/Context: There are not proper controls in place to review invoices and assign them to the appropriate grant period. Two expenditures out of forty non-payroll related expenditures tested for the Crime Victim Assistance grant was for a contracted annual service that covered multiple performance periods but was billed in its entirety to the current fiscal year.
Effect: An overstatement of expenditures for the Crime Victim Assistance grant was reported in the current year.
Recommendation: We recommend procedures are established to review for proper grant period when recording transactions and creating monthly reimbursement requests.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures.
1. The Staff Accountant will review the period each expenditure is related to and record the invoice to the appropriate period when entering it into accounts payable. The month and year will be noted on the invoice.
2. The CFO will review the month and year noted by the Staff Accountant prior to entry into accounts payable.
U.S. Department of Homeland Security, U.S. Department of Justice, and U.S. Department of Health and Human Services
#2023-011 – Major Federal Award Finding
Nature of Finding: Significant Deficiency in Internal Controls over Compliance
This is a repeat of prior year finding #2022-007.
Criteria/Condition: Per 2 CFR 200.510(b), the auditee must prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee's financial statements, which must include the total federal awards expended, as determined in accordance with §200.502. For SEFA reporting, federal expenditures were not disclosed for one program and were overstated or understated for other programs.
Cause/Context: Expenditures for the Emergency Food and Shelter National Board Program were excluded from the client-prepared SEFA. There were various other grants with allocations between state and federal funding that were not presented properly on the SEFA. The SEFA presented has been adjusted for these errors.
Effect: Controls in place did not sufficiently ensure the completeness and accuracy of the SEFA.
Recommendation: We recommend the Organization enhance its procedures and controls to ensure data accumulated to prepare the SEFA is complete and accurate.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
The Schedule of Expenditures of Federal Awards (SEFA) will be reviewed for accuracy by either the CFO or CEO after it is produced, to ensure that all federal awards are included, and that the amounts on the schedule are accurate.
U.S. Department of Justice
Crime Victim Assistance – Assistance #16.575
#2023-008 – Major Federal Award Finding – Reporting
Nature of Finding: Compliance Finding Reporting and Material Weakness in Internal Controls over Compliance
This is a repeat of prior year finding #2022-006.
Criteria/Condition: Federal regulations 2 CFR 200.328 - 200.329 provide that required reporting under the federal program must be completed timely and accurately. The federal award agreement includes specific report filing due dates. Segregation of duties is also a key element of internal controls, including controls over compliance, and involves processes whereby the activities of one employee are reviewed or checked by the activities of another individual, and avoids one employee having the ability to perform a transaction or process from beginning to end. We noted during testing of sixteen different required reports that five of these reports tested were not filed in a timely manner. There were also no review procedures in place surrounding these reports.
Cause/Context: Controls were not in place to ensure timely reporting. Only one individual was involved in the reporting process for the reports. A total of five of the reports tested were submitted more than ten days late.
Effect: A lack of controls could result in late or failed reporting.
Recommendation: We recommend the Organization establish procedures and controls to ensure financial and performance reports are filed timely.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will ensure that all federal award reports are filed in a timely manner. The Organization is in the process of posting a new position, Director of Grants and Compliance. The individual in this new role will be responsible for tracking report due dates and working with the individuals responsible for the content of these reports to ensure the information is accurate and on time. In situations where the Director of Grants and Compliance is responsible for gathering the data for required reporting, the data will be reviewed by either the CFO or CEO prior to submission of the report.
U.S. Department of Justice
Crime Victim Assistance – Assistance #16.575
#2023-009 – Major Federal Award Finding – Cash Management
Nature of Finding: Compliance Finding Cash Management and Significant Deficiency in Internal Controls over Compliance
Criteria/Condition: 2 CFR 200.305 requires that non-federal entities must minimize the time elapsing between the transfer of federal funds to the non-federal entity and the subsequent disbursement of the funds by the non-federal entity for program costs. The Organization did not have proper controls in place to verify that specific vendor invoices were paid within a reasonable amount of time of requesting reimbursement for the expenditures.
Questioned Costs: $2,381
Identification of How Questioned Costs Were Computed: The issues of noncompliance related to cash management was limited to one vendor that was not paid within a reasonable amount of time of being reimbursed for the costs. This was determined to be an isolated incident. Questioned costs include the two invoices that were charged to the grant for this vendor during the year ended September 30, 2023 and were not paid to the vendor within a reasonable amount of time of being reimbursed for the expenditures.
Cause/Context: Controls were not in place to ensure expenditures were paid to the vendor prior to requesting reimbursements. This circumstance was determined to be an isolated incident due to the unique nature of the vendor invoices. The Organization was withholding payment to the vendor until it determined that both invoices were proper.
Effect: The lack of controls could result in requests for reimbursement being submitted for unpaid expenditures.
Recommendation: We recommend the Organization establish procedures and incorporate controls to review that expenditures are paid prior to submitting requests for reimbursement.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
Each month, an aged open accounts payable report will be produced as part of the month end closing. Invoices that are past due will be paid in the following batch of payments (which are typically run weekly). If it is determined that the invoice is not being paid for a valid reason, it will be removed from accounts payable at that time.
U.S. Department of Justice
Crime Victim Assistance – Assistance #16.575
#2023-009 – Major Federal Award Finding – Cash Management
Nature of Finding: Compliance Finding Cash Management and Significant Deficiency in Internal Controls over Compliance
Criteria/Condition: 2 CFR 200.305 requires that non-federal entities must minimize the time elapsing between the transfer of federal funds to the non-federal entity and the subsequent disbursement of the funds by the non-federal entity for program costs. The Organization did not have proper controls in place to verify that specific vendor invoices were paid within a reasonable amount of time of requesting reimbursement for the expenditures.
Questioned Costs: $2,381
Identification of How Questioned Costs Were Computed: The issues of noncompliance related to cash management was limited to one vendor that was not paid within a reasonable amount of time of being reimbursed for the costs. This was determined to be an isolated incident. Questioned costs include the two invoices that were charged to the grant for this vendor during the year ended September 30, 2023 and were not paid to the vendor within a reasonable amount of time of being reimbursed for the expenditures.
Cause/Context: Controls were not in place to ensure expenditures were paid to the vendor prior to requesting reimbursements. This circumstance was determined to be an isolated incident due to the unique nature of the vendor invoices. The Organization was withholding payment to the vendor until it determined that both invoices were proper.
Effect: The lack of controls could result in requests for reimbursement being submitted for unpaid expenditures.
Recommendation: We recommend the Organization establish procedures and incorporate controls to review that expenditures are paid prior to submitting requests for reimbursement.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
Each month, an aged open accounts payable report will be produced as part of the month end closing. Invoices that are past due will be paid in the following batch of payments (which are typically run weekly). If it is determined that the invoice is not being paid for a valid reason, it will be removed from accounts payable at that time.
#2023-010 – Major Federal Award Finding – Period of Performance
Nature of Finding: Compliance Finding Period of Performance and Material Weakness in Internal Controls over Compliance
Criteria/Condition: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance. The Organization did not have controls in place to verify that costs were being charged to the award in the correct period of performance.
Questioned Costs: $20,790
Identification of How Questioned Costs Were Computed: A sample of 40 non-payroll expenditures totaling approximately $48,000 was selected from a population of approximately $552,000 of non-payroll expenditures. An amount of $1,817 combined from two invoices that were charged to the Crime Victim Assistance program was related to the year ending September 30, 2024 and was inappropriately charged to the grant during 2023. Questioned costs are estimated by projecting the error identified in the sample tested to the population of non-payroll expenditures of the Crime Victim Assistance program.
Cause/Context: There are not proper controls in place to review invoices and assign them to the appropriate grant period. Two expenditures out of forty non-payroll related expenditures tested for the Crime Victim Assistance grant was for a contracted annual service that covered multiple performance periods but was billed in its entirety to the current fiscal year.
Effect: An overstatement of expenditures for the Crime Victim Assistance grant was reported in the current year.
Recommendation: We recommend procedures are established to review for proper grant period when recording transactions and creating monthly reimbursement requests.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures.
1. The Staff Accountant will review the period each expenditure is related to and record the invoice to the appropriate period when entering it into accounts payable. The month and year will be noted on the invoice.
2. The CFO will review the month and year noted by the Staff Accountant prior to entry into accounts payable.
U.S. Department of Homeland Security, U.S. Department of Justice, and U.S. Department of Health and Human Services
#2023-011 – Major Federal Award Finding
Nature of Finding: Significant Deficiency in Internal Controls over Compliance
This is a repeat of prior year finding #2022-007.
Criteria/Condition: Per 2 CFR 200.510(b), the auditee must prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee's financial statements, which must include the total federal awards expended, as determined in accordance with §200.502. For SEFA reporting, federal expenditures were not disclosed for one program and were overstated or understated for other programs.
Cause/Context: Expenditures for the Emergency Food and Shelter National Board Program were excluded from the client-prepared SEFA. There were various other grants with allocations between state and federal funding that were not presented properly on the SEFA. The SEFA presented has been adjusted for these errors.
Effect: Controls in place did not sufficiently ensure the completeness and accuracy of the SEFA.
Recommendation: We recommend the Organization enhance its procedures and controls to ensure data accumulated to prepare the SEFA is complete and accurate.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
The Schedule of Expenditures of Federal Awards (SEFA) will be reviewed for accuracy by either the CFO or CEO after it is produced, to ensure that all federal awards are included, and that the amounts on the schedule are accurate.
U.S. Department of Homeland Security, U.S. Department of Justice, and U.S. Department of Health and Human Services
#2023-011 – Major Federal Award Finding
Nature of Finding: Significant Deficiency in Internal Controls over Compliance
This is a repeat of prior year finding #2022-007.
Criteria/Condition: Per 2 CFR 200.510(b), the auditee must prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee's financial statements, which must include the total federal awards expended, as determined in accordance with §200.502. For SEFA reporting, federal expenditures were not disclosed for one program and were overstated or understated for other programs.
Cause/Context: Expenditures for the Emergency Food and Shelter National Board Program were excluded from the client-prepared SEFA. There were various other grants with allocations between state and federal funding that were not presented properly on the SEFA. The SEFA presented has been adjusted for these errors.
Effect: Controls in place did not sufficiently ensure the completeness and accuracy of the SEFA.
Recommendation: We recommend the Organization enhance its procedures and controls to ensure data accumulated to prepare the SEFA is complete and accurate.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
The Schedule of Expenditures of Federal Awards (SEFA) will be reviewed for accuracy by either the CFO or CEO after it is produced, to ensure that all federal awards are included, and that the amounts on the schedule are accurate.
U.S. Department of Homeland Security, U.S. Department of Justice, and U.S. Department of Health and Human Services
#2023-011 – Major Federal Award Finding
Nature of Finding: Significant Deficiency in Internal Controls over Compliance
This is a repeat of prior year finding #2022-007.
Criteria/Condition: Per 2 CFR 200.510(b), the auditee must prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee's financial statements, which must include the total federal awards expended, as determined in accordance with §200.502. For SEFA reporting, federal expenditures were not disclosed for one program and were overstated or understated for other programs.
Cause/Context: Expenditures for the Emergency Food and Shelter National Board Program were excluded from the client-prepared SEFA. There were various other grants with allocations between state and federal funding that were not presented properly on the SEFA. The SEFA presented has been adjusted for these errors.
Effect: Controls in place did not sufficiently ensure the completeness and accuracy of the SEFA.
Recommendation: We recommend the Organization enhance its procedures and controls to ensure data accumulated to prepare the SEFA is complete and accurate.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
The Schedule of Expenditures of Federal Awards (SEFA) will be reviewed for accuracy by either the CFO or CEO after it is produced, to ensure that all federal awards are included, and that the amounts on the schedule are accurate.
U.S. Department of Homeland Security, U.S. Department of Justice, and U.S. Department of Health and Human Services
#2023-011 – Major Federal Award Finding
Nature of Finding: Significant Deficiency in Internal Controls over Compliance
This is a repeat of prior year finding #2022-007.
Criteria/Condition: Per 2 CFR 200.510(b), the auditee must prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee's financial statements, which must include the total federal awards expended, as determined in accordance with §200.502. For SEFA reporting, federal expenditures were not disclosed for one program and were overstated or understated for other programs.
Cause/Context: Expenditures for the Emergency Food and Shelter National Board Program were excluded from the client-prepared SEFA. There were various other grants with allocations between state and federal funding that were not presented properly on the SEFA. The SEFA presented has been adjusted for these errors.
Effect: Controls in place did not sufficiently ensure the completeness and accuracy of the SEFA.
Recommendation: We recommend the Organization enhance its procedures and controls to ensure data accumulated to prepare the SEFA is complete and accurate.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
The Schedule of Expenditures of Federal Awards (SEFA) will be reviewed for accuracy by either the CFO or CEO after it is produced, to ensure that all federal awards are included, and that the amounts on the schedule are accurate.
U.S. Department of Homeland Security, U.S. Department of Justice, and U.S. Department of Health and Human Services
#2023-011 – Major Federal Award Finding
Nature of Finding: Significant Deficiency in Internal Controls over Compliance
This is a repeat of prior year finding #2022-007.
Criteria/Condition: Per 2 CFR 200.510(b), the auditee must prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee's financial statements, which must include the total federal awards expended, as determined in accordance with §200.502. For SEFA reporting, federal expenditures were not disclosed for one program and were overstated or understated for other programs.
Cause/Context: Expenditures for the Emergency Food and Shelter National Board Program were excluded from the client-prepared SEFA. There were various other grants with allocations between state and federal funding that were not presented properly on the SEFA. The SEFA presented has been adjusted for these errors.
Effect: Controls in place did not sufficiently ensure the completeness and accuracy of the SEFA.
Recommendation: We recommend the Organization enhance its procedures and controls to ensure data accumulated to prepare the SEFA is complete and accurate.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
The Schedule of Expenditures of Federal Awards (SEFA) will be reviewed for accuracy by either the CFO or CEO after it is produced, to ensure that all federal awards are included, and that the amounts on the schedule are accurate.
U.S. Department of Homeland Security, U.S. Department of Justice, and U.S. Department of Health and Human Services
#2023-011 – Major Federal Award Finding
Nature of Finding: Significant Deficiency in Internal Controls over Compliance
This is a repeat of prior year finding #2022-007.
Criteria/Condition: Per 2 CFR 200.510(b), the auditee must prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee's financial statements, which must include the total federal awards expended, as determined in accordance with §200.502. For SEFA reporting, federal expenditures were not disclosed for one program and were overstated or understated for other programs.
Cause/Context: Expenditures for the Emergency Food and Shelter National Board Program were excluded from the client-prepared SEFA. There were various other grants with allocations between state and federal funding that were not presented properly on the SEFA. The SEFA presented has been adjusted for these errors.
Effect: Controls in place did not sufficiently ensure the completeness and accuracy of the SEFA.
Recommendation: We recommend the Organization enhance its procedures and controls to ensure data accumulated to prepare the SEFA is complete and accurate.
Views of Responsible Officials and Planned Corrective Actions:
The Organization will implement the following changes in its accounting procedures:
The Schedule of Expenditures of Federal Awards (SEFA) will be reviewed for accuracy by either the CFO or CEO after it is produced, to ensure that all federal awards are included, and that the amounts on the schedule are accurate.
#2023-004 – Material Weakness: Independent Review and Approval
Condition and Criteria: Independent reviews and approvals are not performed for all significant accounting activities. A procedure should be in place for independent reviews and approvals of significant accounting activities. For all activities, no one individual should have access that allows initiating, recording, authorizing, and reconciling a transaction.
Cause/Context: The following transactions are performed without independent review and approval:
• Journal entries are posted without a review or approval process.
• Formal review of payroll registers is not documented.
• Invoices are not regularly reviewed and approved by appropriate department directors. Invoices are also entered into the general ledger with no independent review of the entry.
• Percentages used to allocate expenses across grants are not reviewed on at least an annual basis.
• Matching amounts required for grants are not independently tracked and reviewed to ensure compliance.
Effect: Unauthorized, erroneous, or inappropriate transactions could occur and go unnoticed.
Recommendation: The Organization should establish review procedures such that all transactions have proper approval.Views of Responsible Officials and Planned Corrective Actions:
The YWCA will implement the following changes in its accounting procedures:
1. Journal entries will be drafted by the Staff Accountant and reviewed by the CFO prior to being posted to the general ledger. The end-of-month-journal-entry spreadsheets will have spaces added for the CFO to indicate approval and date approved.
2. Payroll registers will be reviewed by the CFO each payroll. The end-of-month payroll entry (which encompasses all the payroll entries for the month) will be reviewed by the CFO prior to being uploaded to the MIP accounting software.
3. All invoices will be approved by the appropriate program director and account distribution will be reviewed by the CFO prior to entry into the accounts payable system. 4. Percentages used to allocate expenses across grants will be reviewed and updated annually at the beginning of the fiscal year. The allocation will be approved by the CEO.
5. Matching amounts for grants will be tracked and documented with supporting documentation by the Director of Finance and saved in the appropriate folder within the Finance SharePoint folder
#2023-004 – Material Weakness: Independent Review and Approval
Condition and Criteria: Independent reviews and approvals are not performed for all significant accounting activities. A procedure should be in place for independent reviews and approvals of significant accounting activities. For all activities, no one individual should have access that allows initiating, recording, authorizing, and reconciling a transaction.
Cause/Context: The following transactions are performed without independent review and approval:
• Journal entries are posted without a review or approval process.
• Formal review of payroll registers is not documented.
• Invoices are not regularly reviewed and approved by appropriate department directors. Invoices are also entered into the general ledger with no independent review of the entry.
• Percentages used to allocate expenses across grants are not reviewed on at least an annual basis.
• Matching amounts required for grants are not independently tracked and reviewed to ensure compliance.
Effect: Unauthorized, erroneous, or inappropriate transactions could occur and go unnoticed.
Recommendation: The Organization should establish review procedures such that all transactions have proper approval.Views of Responsible Officials and Planned Corrective Actions:
The YWCA will implement the following changes in its accounting procedures:
1. Journal entries will be drafted by the Staff Accountant and reviewed by the CFO prior to being posted to the general ledger. The end-of-month-journal-entry spreadsheets will have spaces added for the CFO to indicate approval and date approved.
2. Payroll registers will be reviewed by the CFO each payroll. The end-of-month payroll entry (which encompasses all the payroll entries for the month) will be reviewed by the CFO prior to being uploaded to the MIP accounting software.
3. All invoices will be approved by the appropriate program director and account distribution will be reviewed by the CFO prior to entry into the accounts payable system. 4. Percentages used to allocate expenses across grants will be reviewed and updated annually at the beginning of the fiscal year. The allocation will be approved by the CEO.
5. Matching amounts for grants will be tracked and documented with supporting documentation by the Director of Finance and saved in the appropriate folder within the Finance SharePoint folder
#2023-004 – Material Weakness: Independent Review and Approval
Condition and Criteria: Independent reviews and approvals are not performed for all significant accounting activities. A procedure should be in place for independent reviews and approvals of significant accounting activities. For all activities, no one individual should have access that allows initiating, recording, authorizing, and reconciling a transaction.
Cause/Context: The following transactions are performed without independent review and approval:
• Journal entries are posted without a review or approval process.
• Formal review of payroll registers is not documented.
• Invoices are not regularly reviewed and approved by appropriate department directors. Invoices are also entered into the general ledger with no independent review of the entry.
• Percentages used to allocate expenses across grants are not reviewed on at least an annual basis.
• Matching amounts required for grants are not independently tracked and reviewed to ensure compliance.
Effect: Unauthorized, erroneous, or inappropriate transactions could occur and go unnoticed.
Recommendation: The Organization should establish review procedures such that all transactions have proper approval.Views of Responsible Officials and Planned Corrective Actions:
The YWCA will implement the following changes in its accounting procedures:
1. Journal entries will be drafted by the Staff Accountant and reviewed by the CFO prior to being posted to the general ledger. The end-of-month-journal-entry spreadsheets will have spaces added for the CFO to indicate approval and date approved.
2. Payroll registers will be reviewed by the CFO each payroll. The end-of-month payroll entry (which encompasses all the payroll entries for the month) will be reviewed by the CFO prior to being uploaded to the MIP accounting software.
3. All invoices will be approved by the appropriate program director and account distribution will be reviewed by the CFO prior to entry into the accounts payable system. 4. Percentages used to allocate expenses across grants will be reviewed and updated annually at the beginning of the fiscal year. The allocation will be approved by the CEO.
5. Matching amounts for grants will be tracked and documented with supporting documentation by the Director of Finance and saved in the appropriate folder within the Finance SharePoint folder
#2023-004 – Material Weakness: Independent Review and Approval
Condition and Criteria: Independent reviews and approvals are not performed for all significant accounting activities. A procedure should be in place for independent reviews and approvals of significant accounting activities. For all activities, no one individual should have access that allows initiating, recording, authorizing, and reconciling a transaction.
Cause/Context: The following transactions are performed without independent review and approval:
• Journal entries are posted without a review or approval process.
• Formal review of payroll registers is not documented.
• Invoices are not regularly reviewed and approved by appropriate department directors. Invoices are also entered into the general ledger with no independent review of the entry.
• Percentages used to allocate expenses across grants are not reviewed on at least an annual basis.
• Matching amounts required for grants are not independently tracked and reviewed to ensure compliance.
Effect: Unauthorized, erroneous, or inappropriate transactions could occur and go unnoticed.
Recommendation: The Organization should establish review procedures such that all transactions have proper approval.Views of Responsible Officials and Planned Corrective Actions:
The YWCA will implement the following changes in its accounting procedures:
1. Journal entries will be drafted by the Staff Accountant and reviewed by the CFO prior to being posted to the general ledger. The end-of-month-journal-entry spreadsheets will have spaces added for the CFO to indicate approval and date approved.
2. Payroll registers will be reviewed by the CFO each payroll. The end-of-month payroll entry (which encompasses all the payroll entries for the month) will be reviewed by the CFO prior to being uploaded to the MIP accounting software.
3. All invoices will be approved by the appropriate program director and account distribution will be reviewed by the CFO prior to entry into the accounts payable system. 4. Percentages used to allocate expenses across grants will be reviewed and updated annually at the beginning of the fiscal year. The allocation will be approved by the CEO.
5. Matching amounts for grants will be tracked and documented with supporting documentation by the Director of Finance and saved in the appropriate folder within the Finance SharePoint folder
#2023-004 – Material Weakness: Independent Review and Approval
Condition and Criteria: Independent reviews and approvals are not performed for all significant accounting activities. A procedure should be in place for independent reviews and approvals of significant accounting activities. For all activities, no one individual should have access that allows initiating, recording, authorizing, and reconciling a transaction.
Cause/Context: The following transactions are performed without independent review and approval:
• Journal entries are posted without a review or approval process.
• Formal review of payroll registers is not documented.
• Invoices are not regularly reviewed and approved by appropriate department directors. Invoices are also entered into the general ledger with no independent review of the entry.
• Percentages used to allocate expenses across grants are not reviewed on at least an annual basis.
• Matching amounts required for grants are not independently tracked and reviewed to ensure compliance.
Effect: Unauthorized, erroneous, or inappropriate transactions could occur and go unnoticed.
Recommendation: The Organization should establish review procedures such that all transactions have proper approval.Views of Responsible Officials and Planned Corrective Actions:
The YWCA will implement the following changes in its accounting procedures:
1. Journal entries will be drafted by the Staff Accountant and reviewed by the CFO prior to being posted to the general ledger. The end-of-month-journal-entry spreadsheets will have spaces added for the CFO to indicate approval and date approved.
2. Payroll registers will be reviewed by the CFO each payroll. The end-of-month payroll entry (which encompasses all the payroll entries for the month) will be reviewed by the CFO prior to being uploaded to the MIP accounting software.
3. All invoices will be approved by the appropriate program director and account distribution will be reviewed by the CFO prior to entry into the accounts payable system. 4. Percentages used to allocate expenses across grants will be reviewed and updated annually at the beginning of the fiscal year. The allocation will be approved by the CEO.
5. Matching amounts for grants will be tracked and documented with supporting documentation by the Director of Finance and saved in the appropriate folder within the Finance SharePoint folder
#2023-004 – Material Weakness: Independent Review and Approval
Condition and Criteria: Independent reviews and approvals are not performed for all significant accounting activities. A procedure should be in place for independent reviews and approvals of significant accounting activities. For all activities, no one individual should have access that allows initiating, recording, authorizing, and reconciling a transaction.
Cause/Context: The following transactions are performed without independent review and approval:
• Journal entries are posted without a review or approval process.
• Formal review of payroll registers is not documented.
• Invoices are not regularly reviewed and approved by appropriate department directors. Invoices are also entered into the general ledger with no independent review of the entry.
• Percentages used to allocate expenses across grants are not reviewed on at least an annual basis.
• Matching amounts required for grants are not independently tracked and reviewed to ensure compliance.
Effect: Unauthorized, erroneous, or inappropriate transactions could occur and go unnoticed.
Recommendation: The Organization should establish review procedures such that all transactions have proper approval.Views of Responsible Officials and Planned Corrective Actions:
The YWCA will implement the following changes in its accounting procedures:
1. Journal entries will be drafted by the Staff Accountant and reviewed by the CFO prior to being posted to the general ledger. The end-of-month-journal-entry spreadsheets will have spaces added for the CFO to indicate approval and date approved.
2. Payroll registers will be reviewed by the CFO each payroll. The end-of-month payroll entry (which encompasses all the payroll entries for the month) will be reviewed by the CFO prior to being uploaded to the MIP accounting software.
3. All invoices will be approved by the appropriate program director and account distribution will be reviewed by the CFO prior to entry into the accounts payable system. 4. Percentages used to allocate expenses across grants will be reviewed and updated annually at the beginning of the fiscal year. The allocation will be approved by the CEO.
5. Matching amounts for grants will be tracked and documented with supporting documentation by the Director of Finance and saved in the appropriate folder within the Finance SharePoint folder
#2023-004 – Material Weakness: Independent Review and Approval
Condition and Criteria: Independent reviews and approvals are not performed for all significant accounting activities. A procedure should be in place for independent reviews and approvals of significant accounting activities. For all activities, no one individual should have access that allows initiating, recording, authorizing, and reconciling a transaction.
Cause/Context: The following transactions are performed without independent review and approval:
• Journal entries are posted without a review or approval process.
• Formal review of payroll registers is not documented.
• Invoices are not regularly reviewed and approved by appropriate department directors. Invoices are also entered into the general ledger with no independent review of the entry.
• Percentages used to allocate expenses across grants are not reviewed on at least an annual basis.
• Matching amounts required for grants are not independently tracked and reviewed to ensure compliance.
Effect: Unauthorized, erroneous, or inappropriate transactions could occur and go unnoticed.
Recommendation: The Organization should establish review procedures such that all transactions have proper approval.Views of Responsible Officials and Planned Corrective Actions:
The YWCA will implement the following changes in its accounting procedures:
1. Journal entries will be drafted by the Staff Accountant and reviewed by the CFO prior to being posted to the general ledger. The end-of-month-journal-entry spreadsheets will have spaces added for the CFO to indicate approval and date approved.
2. Payroll registers will be reviewed by the CFO each payroll. The end-of-month payroll entry (which encompasses all the payroll entries for the month) will be reviewed by the CFO prior to being uploaded to the MIP accounting software.
3. All invoices will be approved by the appropriate program director and account distribution will be reviewed by the CFO prior to entry into the accounts payable system. 4. Percentages used to allocate expenses across grants will be reviewed and updated annually at the beginning of the fiscal year. The allocation will be approved by the CEO.
5. Matching amounts for grants will be tracked and documented with supporting documentation by the Director of Finance and saved in the appropriate folder within the Finance SharePoint folder
#2023-004 – Material Weakness: Independent Review and Approval
Condition and Criteria: Independent reviews and approvals are not performed for all significant accounting activities. A procedure should be in place for independent reviews and approvals of significant accounting activities. For all activities, no one individual should have access that allows initiating, recording, authorizing, and reconciling a transaction.
Cause/Context: The following transactions are performed without independent review and approval:
• Journal entries are posted without a review or approval process.
• Formal review of payroll registers is not documented.
• Invoices are not regularly reviewed and approved by appropriate department directors. Invoices are also entered into the general ledger with no independent review of the entry.
• Percentages used to allocate expenses across grants are not reviewed on at least an annual basis.
• Matching amounts required for grants are not independently tracked and reviewed to ensure compliance.
Effect: Unauthorized, erroneous, or inappropriate transactions could occur and go unnoticed.
Recommendation: The Organization should establish review procedures such that all transactions have proper approval.Views of Responsible Officials and Planned Corrective Actions:
The YWCA will implement the following changes in its accounting procedures:
1. Journal entries will be drafted by the Staff Accountant and reviewed by the CFO prior to being posted to the general ledger. The end-of-month-journal-entry spreadsheets will have spaces added for the CFO to indicate approval and date approved.
2. Payroll registers will be reviewed by the CFO each payroll. The end-of-month payroll entry (which encompasses all the payroll entries for the month) will be reviewed by the CFO prior to being uploaded to the MIP accounting software.
3. All invoices will be approved by the appropriate program director and account distribution will be reviewed by the CFO prior to entry into the accounts payable system. 4. Percentages used to allocate expenses across grants will be reviewed and updated annually at the beginning of the fiscal year. The allocation will be approved by the CEO.
5. Matching amounts for grants will be tracked and documented with supporting documentation by the Director of Finance and saved in the appropriate folder within the Finance SharePoint folder
#2023-004 – Material Weakness: Independent Review and Approval
Condition and Criteria: Independent reviews and approvals are not performed for all significant accounting activities. A procedure should be in place for independent reviews and approvals of significant accounting activities. For all activities, no one individual should have access that allows initiating, recording, authorizing, and reconciling a transaction.
Cause/Context: The following transactions are performed without independent review and approval:
• Journal entries are posted without a review or approval process.
• Formal review of payroll registers is not documented.
• Invoices are not regularly reviewed and approved by appropriate department directors. Invoices are also entered into the general ledger with no independent review of the entry.
• Percentages used to allocate expenses across grants are not reviewed on at least an annual basis.
• Matching amounts required for grants are not independently tracked and reviewed to ensure compliance.
Effect: Unauthorized, erroneous, or inappropriate transactions could occur and go unnoticed.
Recommendation: The Organization should establish review procedures such that all transactions have proper approval.Views of Responsible Officials and Planned Corrective Actions:
The YWCA will implement the following changes in its accounting procedures:
1. Journal entries will be drafted by the Staff Accountant and reviewed by the CFO prior to being posted to the general ledger. The end-of-month-journal-entry spreadsheets will have spaces added for the CFO to indicate approval and date approved.
2. Payroll registers will be reviewed by the CFO each payroll. The end-of-month payroll entry (which encompasses all the payroll entries for the month) will be reviewed by the CFO prior to being uploaded to the MIP accounting software.
3. All invoices will be approved by the appropriate program director and account distribution will be reviewed by the CFO prior to entry into the accounts payable system. 4. Percentages used to allocate expenses across grants will be reviewed and updated annually at the beginning of the fiscal year. The allocation will be approved by the CEO.
5. Matching amounts for grants will be tracked and documented with supporting documentation by the Director of Finance and saved in the appropriate folder within the Finance SharePoint folder
#2023-004 – Material Weakness: Independent Review and Approval
Condition and Criteria: Independent reviews and approvals are not performed for all significant accounting activities. A procedure should be in place for independent reviews and approvals of significant accounting activities. For all activities, no one individual should have access that allows initiating, recording, authorizing, and reconciling a transaction.
Cause/Context: The following transactions are performed without independent review and approval:
• Journal entries are posted without a review or approval process.
• Formal review of payroll registers is not documented.
• Invoices are not regularly reviewed and approved by appropriate department directors. Invoices are also entered into the general ledger with no independent review of the entry.
• Percentages used to allocate expenses across grants are not reviewed on at least an annual basis.
• Matching amounts required for grants are not independently tracked and reviewed to ensure compliance.
Effect: Unauthorized, erroneous, or inappropriate transactions could occur and go unnoticed.
Recommendation: The Organization should establish review procedures such that all transactions have proper approval.Views of Responsible Officials and Planned Corrective Actions:
The YWCA will implement the following changes in its accounting procedures:
1. Journal entries will be drafted by the Staff Accountant and reviewed by the CFO prior to being posted to the general ledger. The end-of-month-journal-entry spreadsheets will have spaces added for the CFO to indicate approval and date approved.
2. Payroll registers will be reviewed by the CFO each payroll. The end-of-month payroll entry (which encompasses all the payroll entries for the month) will be reviewed by the CFO prior to being uploaded to the MIP accounting software.
3. All invoices will be approved by the appropriate program director and account distribution will be reviewed by the CFO prior to entry into the accounts payable system. 4. Percentages used to allocate expenses across grants will be reviewed and updated annually at the beginning of the fiscal year. The allocation will be approved by the CEO.
5. Matching amounts for grants will be tracked and documented with supporting documentation by the Director of Finance and saved in the appropriate folder within the Finance SharePoint folder