Audit 30918

Criteria: 2 CFR 200.303 includes requirements related to internal controls for federal award programs, including that the Agency must, among other things, ?establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)?. Condition and Context: The Center did not retain formal documentation of the Controller?s review of federal expenditures for allowable costs/cost principles. The Controller?s review was key to the internal control process as it covered an overview of the expenses charged to the Shutter Venue Operators Grant (SVOG). The Center had other key controls in place over compliance which appeared to be operating effectively. However, the Controller?s the other key controls were meant to prevent unallowable costs and activities for routine transactions. The Controller?s review was the only key control noted to detect noncompliance of nonroutine transactions. Cause and Effect: No noncompliance was noted; however, noncompliance could have occurred which was not detected. Recommendation: We recommend the Center implement procedures to document all internal control processes performed by the Center. Views of Responsible Officials and Planned Corrective Actions: The Center agrees with the recommendation and plans to implement the recommendation by May 31, 2023.

Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-Federal entities receiving Federal funds to have certain written policies, procedures, and standards of conduct (policies) in place. Condition and Context: The Center does not have the written policies in place in accordance with ?200.302 Financial Management paragraph (b)(7). Cause and Effect: As the policies referenced above are not written, the Center cannot be in compliance with the requirements. In addition, lack of written policies related to financial management may lead to noncompliance with allowable costs/cost principles requirements. Recommendation: We recommend the policies in accordance with ?200.302 Financial Management paragraph (b)(7) be written by the Center, approved by the Board of Directors, and included in the permanent files of the Center. Views of Responsible Officials and Planned Corrective Actions: The Center agrees with the recommendation and plans to implement the recommendation by May 31, 2023.

Criteria: 2 CFR 200.303 includes requirements related to internal controls for federal award programs, including that the Agency must, among other things, ?establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)?. Condition and Context: The Center did not retain formal documentation of the Controller?s review of federal expenditures for allowable costs/cost principles. The Controller?s review was key to the internal control process as it covered an overview of the expenses charged to the Shutter Venue Operators Grant (SVOG). The Center had other key controls in place over compliance which appeared to be operating effectively. However, the Controller?s the other key controls were meant to prevent unallowable costs and activities for routine transactions. The Controller?s review was the only key control noted to detect noncompliance of nonroutine transactions. Cause and Effect: No noncompliance was noted; however, noncompliance could have occurred which was not detected. Recommendation: We recommend the Center implement procedures to document all internal control processes performed by the Center. Views of Responsible Officials and Planned Corrective Actions: The Center agrees with the recommendation and plans to implement the recommendation by May 31, 2023.

Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-Federal entities receiving Federal funds to have certain written policies, procedures, and standards of conduct (policies) in place. Condition and Context: The Center does not have the written policies in place in accordance with ?200.302 Financial Management paragraph (b)(7). Cause and Effect: As the policies referenced above are not written, the Center cannot be in compliance with the requirements. In addition, lack of written policies related to financial management may lead to noncompliance with allowable costs/cost principles requirements. Recommendation: We recommend the policies in accordance with ?200.302 Financial Management paragraph (b)(7) be written by the Center, approved by the Board of Directors, and included in the permanent files of the Center. Views of Responsible Officials and Planned Corrective Actions: The Center agrees with the recommendation and plans to implement the recommendation by May 31, 2023.