Finding 2023-001: Preparation of Schedule of Expenditures of Federal Awards (SEFA)
Information on the Federal Programs: All
Criteria: As noted in 2 CFR 200.508 “Auditee Responsibilities” indicates that the auditee must prepare
appropriate financial statements, including the Schedule of Expenditures of Federal Awards (as
specifically defined under 2 CFR 200.510 “Financial statements”). Title 2 CFR 200 Section 200.510
“Financial Statements” requires recipients of Federal funds to 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. Additionally, in accordance with CFR 200.303, the non-
Federal entity must: 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.
Condition: Accountability Lab experienced difficulty in preparing and ensuring that all Federal
expenditures were identified, categorized, and included in the Schedule of Expenditures of Federal
Awards. The preparation of Accountability Lab's SEFA required manual adjustments of Federal costs.
We noted that the manual adjustments were not completed prior to the start of the audit. We also
noted that a certain award was not clearly identified as Federal pass-through funds and therefore not
initially included on the SEFA. As a result, several adjustments were posted to the financial statements
to ensure Federal receivables, refundable advances and Federal revenue were properly recognized
and accurately stated at year-end.
Cause: The year-end close process did not provide for the preparation of a complete and accurate
schedule of expenditures of Federal awards.
Effect: Without periodic training and consistent application of Accountability Lab’s internal policies and
procedures, this could potentially result in unreliable and erroneous grant reporting, internal record
keeping and decision making.
Questioned Costs: None noted.
Context: Our audit testwork consisted of substantive procedures over the SEFA. We determined that
the issue was systemic in nature.
Identification as a Repeat Finding: Not applicable.
Recommendation: We recommend Accountability Lab establish internal controls to correctly identify
and track all Federal awards received either directly or indirectly.
Finding 2023-001: Preparation of Schedule of Expenditures of Federal Awards (SEFA)
Information on the Federal Programs: All
Criteria: As noted in 2 CFR 200.508 “Auditee Responsibilities” indicates that the auditee must prepare
appropriate financial statements, including the Schedule of Expenditures of Federal Awards (as
specifically defined under 2 CFR 200.510 “Financial statements”). Title 2 CFR 200 Section 200.510
“Financial Statements” requires recipients of Federal funds to 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. Additionally, in accordance with CFR 200.303, the non-
Federal entity must: 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.
Condition: Accountability Lab experienced difficulty in preparing and ensuring that all Federal
expenditures were identified, categorized, and included in the Schedule of Expenditures of Federal
Awards. The preparation of Accountability Lab's SEFA required manual adjustments of Federal costs.
We noted that the manual adjustments were not completed prior to the start of the audit. We also
noted that a certain award was not clearly identified as Federal pass-through funds and therefore not
initially included on the SEFA. As a result, several adjustments were posted to the financial statements
to ensure Federal receivables, refundable advances and Federal revenue were properly recognized
and accurately stated at year-end.
Cause: The year-end close process did not provide for the preparation of a complete and accurate
schedule of expenditures of Federal awards.
Effect: Without periodic training and consistent application of Accountability Lab’s internal policies and
procedures, this could potentially result in unreliable and erroneous grant reporting, internal record
keeping and decision making.
Questioned Costs: None noted.
Context: Our audit testwork consisted of substantive procedures over the SEFA. We determined that
the issue was systemic in nature.
Identification as a Repeat Finding: Not applicable.
Recommendation: We recommend Accountability Lab establish internal controls to correctly identify
and track all Federal awards received either directly or indirectly.
Finding 2023-001: Preparation of Schedule of Expenditures of Federal Awards (SEFA)
Information on the Federal Programs: All
Criteria: As noted in 2 CFR 200.508 “Auditee Responsibilities” indicates that the auditee must prepare
appropriate financial statements, including the Schedule of Expenditures of Federal Awards (as
specifically defined under 2 CFR 200.510 “Financial statements”). Title 2 CFR 200 Section 200.510
“Financial Statements” requires recipients of Federal funds to 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. Additionally, in accordance with CFR 200.303, the non-
Federal entity must: 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.
Condition: Accountability Lab experienced difficulty in preparing and ensuring that all Federal
expenditures were identified, categorized, and included in the Schedule of Expenditures of Federal
Awards. The preparation of Accountability Lab's SEFA required manual adjustments of Federal costs.
We noted that the manual adjustments were not completed prior to the start of the audit. We also
noted that a certain award was not clearly identified as Federal pass-through funds and therefore not
initially included on the SEFA. As a result, several adjustments were posted to the financial statements
to ensure Federal receivables, refundable advances and Federal revenue were properly recognized
and accurately stated at year-end.
Cause: The year-end close process did not provide for the preparation of a complete and accurate
schedule of expenditures of Federal awards.
Effect: Without periodic training and consistent application of Accountability Lab’s internal policies and
procedures, this could potentially result in unreliable and erroneous grant reporting, internal record
keeping and decision making.
Questioned Costs: None noted.
Context: Our audit testwork consisted of substantive procedures over the SEFA. We determined that
the issue was systemic in nature.
Identification as a Repeat Finding: Not applicable.
Recommendation: We recommend Accountability Lab establish internal controls to correctly identify
and track all Federal awards received either directly or indirectly.
Finding 2023-002: Subrecipient Monitoring - Review of Audit Reports
Information on the Federal Program: Assistance Listing Numbers 19.705 and 19.345
Criteria: As stated in 2 CFR 200.332(f), all pass-through entities must verify that every subrecipient is
audited as required by 2 CFR 200 Subpart F when it is expected that the subrecipient's Federal awards
expended during the respective fiscal year equaled or exceeded the threshold for triggering such an
audit.
Condition: We were unable to determine whether Accountability Lab performed procedures to verify
whether or not its subrecipients were subject to a compliance audit in accordance with 2 CFR 200
Subpart F.
Cause: Accountability Lab does not have a formal/regularized process in place to monitor subrecipient
audit requirements.
Effect: Accountability Lab's current practices do not provide sufficient documentation to demonstrate
its compliance with the requirements to obtain and review subrecipient audit reports.
Questioned Costs: None noted.
Context: Our audit work included three subrecipients across two major programs. For two out of the
three subrecipients tested, we were not able to verify whether or not Accountability Lab obtained and
reviewed the subrecipient audit reports.
Identification as a Repeat Finding: Not applicable.
Recommendation: Accountability Lab should implement a "Review of Subrecipient Audit" form, to be
completed annually for each subrecipient that receives U.S. Government funding. The form should
document a) the subrecipient's name; b) the annual amount of U.S. Government funds expended by
the subrecipient; c) whether the subrecipient was subject to a U.S. Government compliance audit
under 2 CFR 200 Subpart F; and d) Accountability Lab's formal review of the audit report as well as its
conclusions and follow up on any reported findings, if applicable.
Finding 2023-001: Preparation of Schedule of Expenditures of Federal Awards (SEFA)
Information on the Federal Programs: All
Criteria: As noted in 2 CFR 200.508 “Auditee Responsibilities” indicates that the auditee must prepare
appropriate financial statements, including the Schedule of Expenditures of Federal Awards (as
specifically defined under 2 CFR 200.510 “Financial statements”). Title 2 CFR 200 Section 200.510
“Financial Statements” requires recipients of Federal funds to 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. Additionally, in accordance with CFR 200.303, the non-
Federal entity must: 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.
Condition: Accountability Lab experienced difficulty in preparing and ensuring that all Federal
expenditures were identified, categorized, and included in the Schedule of Expenditures of Federal
Awards. The preparation of Accountability Lab's SEFA required manual adjustments of Federal costs.
We noted that the manual adjustments were not completed prior to the start of the audit. We also
noted that a certain award was not clearly identified as Federal pass-through funds and therefore not
initially included on the SEFA. As a result, several adjustments were posted to the financial statements
to ensure Federal receivables, refundable advances and Federal revenue were properly recognized
and accurately stated at year-end.
Cause: The year-end close process did not provide for the preparation of a complete and accurate
schedule of expenditures of Federal awards.
Effect: Without periodic training and consistent application of Accountability Lab’s internal policies and
procedures, this could potentially result in unreliable and erroneous grant reporting, internal record
keeping and decision making.
Questioned Costs: None noted.
Context: Our audit testwork consisted of substantive procedures over the SEFA. We determined that
the issue was systemic in nature.
Identification as a Repeat Finding: Not applicable.
Recommendation: We recommend Accountability Lab establish internal controls to correctly identify
and track all Federal awards received either directly or indirectly.
Finding 2023-002: Subrecipient Monitoring - Review of Audit Reports
Information on the Federal Program: Assistance Listing Numbers 19.705 and 19.345
Criteria: As stated in 2 CFR 200.332(f), all pass-through entities must verify that every subrecipient is
audited as required by 2 CFR 200 Subpart F when it is expected that the subrecipient's Federal awards
expended during the respective fiscal year equaled or exceeded the threshold for triggering such an
audit.
Condition: We were unable to determine whether Accountability Lab performed procedures to verify
whether or not its subrecipients were subject to a compliance audit in accordance with 2 CFR 200
Subpart F.
Cause: Accountability Lab does not have a formal/regularized process in place to monitor subrecipient
audit requirements.
Effect: Accountability Lab's current practices do not provide sufficient documentation to demonstrate
its compliance with the requirements to obtain and review subrecipient audit reports.
Questioned Costs: None noted.
Context: Our audit work included three subrecipients across two major programs. For two out of the
three subrecipients tested, we were not able to verify whether or not Accountability Lab obtained and
reviewed the subrecipient audit reports.
Identification as a Repeat Finding: Not applicable.
Recommendation: Accountability Lab should implement a "Review of Subrecipient Audit" form, to be
completed annually for each subrecipient that receives U.S. Government funding. The form should
document a) the subrecipient's name; b) the annual amount of U.S. Government funds expended by
the subrecipient; c) whether the subrecipient was subject to a U.S. Government compliance audit
under 2 CFR 200 Subpart F; and d) Accountability Lab's formal review of the audit report as well as its
conclusions and follow up on any reported findings, if applicable.
Finding 2023-001: Preparation of Schedule of Expenditures of Federal Awards (SEFA)
Information on the Federal Programs: All
Criteria: As noted in 2 CFR 200.508 “Auditee Responsibilities” indicates that the auditee must prepare
appropriate financial statements, including the Schedule of Expenditures of Federal Awards (as
specifically defined under 2 CFR 200.510 “Financial statements”). Title 2 CFR 200 Section 200.510
“Financial Statements” requires recipients of Federal funds to 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. Additionally, in accordance with CFR 200.303, the non-
Federal entity must: 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.
Condition: Accountability Lab experienced difficulty in preparing and ensuring that all Federal
expenditures were identified, categorized, and included in the Schedule of Expenditures of Federal
Awards. The preparation of Accountability Lab's SEFA required manual adjustments of Federal costs.
We noted that the manual adjustments were not completed prior to the start of the audit. We also
noted that a certain award was not clearly identified as Federal pass-through funds and therefore not
initially included on the SEFA. As a result, several adjustments were posted to the financial statements
to ensure Federal receivables, refundable advances and Federal revenue were properly recognized
and accurately stated at year-end.
Cause: The year-end close process did not provide for the preparation of a complete and accurate
schedule of expenditures of Federal awards.
Effect: Without periodic training and consistent application of Accountability Lab’s internal policies and
procedures, this could potentially result in unreliable and erroneous grant reporting, internal record
keeping and decision making.
Questioned Costs: None noted.
Context: Our audit testwork consisted of substantive procedures over the SEFA. We determined that
the issue was systemic in nature.
Identification as a Repeat Finding: Not applicable.
Recommendation: We recommend Accountability Lab establish internal controls to correctly identify
and track all Federal awards received either directly or indirectly.
Finding 2023-001: Preparation of Schedule of Expenditures of Federal Awards (SEFA)
Information on the Federal Programs: All
Criteria: As noted in 2 CFR 200.508 “Auditee Responsibilities” indicates that the auditee must prepare
appropriate financial statements, including the Schedule of Expenditures of Federal Awards (as
specifically defined under 2 CFR 200.510 “Financial statements”). Title 2 CFR 200 Section 200.510
“Financial Statements” requires recipients of Federal funds to 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. Additionally, in accordance with CFR 200.303, the non-
Federal entity must: 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.
Condition: Accountability Lab experienced difficulty in preparing and ensuring that all Federal
expenditures were identified, categorized, and included in the Schedule of Expenditures of Federal
Awards. The preparation of Accountability Lab's SEFA required manual adjustments of Federal costs.
We noted that the manual adjustments were not completed prior to the start of the audit. We also
noted that a certain award was not clearly identified as Federal pass-through funds and therefore not
initially included on the SEFA. As a result, several adjustments were posted to the financial statements
to ensure Federal receivables, refundable advances and Federal revenue were properly recognized
and accurately stated at year-end.
Cause: The year-end close process did not provide for the preparation of a complete and accurate
schedule of expenditures of Federal awards.
Effect: Without periodic training and consistent application of Accountability Lab’s internal policies and
procedures, this could potentially result in unreliable and erroneous grant reporting, internal record
keeping and decision making.
Questioned Costs: None noted.
Context: Our audit testwork consisted of substantive procedures over the SEFA. We determined that
the issue was systemic in nature.
Identification as a Repeat Finding: Not applicable.
Recommendation: We recommend Accountability Lab establish internal controls to correctly identify
and track all Federal awards received either directly or indirectly.
Finding 2023-002: Subrecipient Monitoring - Review of Audit Reports
Information on the Federal Program: Assistance Listing Numbers 19.705 and 19.345
Criteria: As stated in 2 CFR 200.332(f), all pass-through entities must verify that every subrecipient is
audited as required by 2 CFR 200 Subpart F when it is expected that the subrecipient's Federal awards
expended during the respective fiscal year equaled or exceeded the threshold for triggering such an
audit.
Condition: We were unable to determine whether Accountability Lab performed procedures to verify
whether or not its subrecipients were subject to a compliance audit in accordance with 2 CFR 200
Subpart F.
Cause: Accountability Lab does not have a formal/regularized process in place to monitor subrecipient
audit requirements.
Effect: Accountability Lab's current practices do not provide sufficient documentation to demonstrate
its compliance with the requirements to obtain and review subrecipient audit reports.
Questioned Costs: None noted.
Context: Our audit work included three subrecipients across two major programs. For two out of the
three subrecipients tested, we were not able to verify whether or not Accountability Lab obtained and
reviewed the subrecipient audit reports.
Identification as a Repeat Finding: Not applicable.
Recommendation: Accountability Lab should implement a "Review of Subrecipient Audit" form, to be
completed annually for each subrecipient that receives U.S. Government funding. The form should
document a) the subrecipient's name; b) the annual amount of U.S. Government funds expended by
the subrecipient; c) whether the subrecipient was subject to a U.S. Government compliance audit
under 2 CFR 200 Subpart F; and d) Accountability Lab's formal review of the audit report as well as its
conclusions and follow up on any reported findings, if applicable.
Finding 2023-001: Preparation of Schedule of Expenditures of Federal Awards (SEFA)
Information on the Federal Programs: All
Criteria: As noted in 2 CFR 200.508 “Auditee Responsibilities” indicates that the auditee must prepare
appropriate financial statements, including the Schedule of Expenditures of Federal Awards (as
specifically defined under 2 CFR 200.510 “Financial statements”). Title 2 CFR 200 Section 200.510
“Financial Statements” requires recipients of Federal funds to 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. Additionally, in accordance with CFR 200.303, the non-
Federal entity must: 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.
Condition: Accountability Lab experienced difficulty in preparing and ensuring that all Federal
expenditures were identified, categorized, and included in the Schedule of Expenditures of Federal
Awards. The preparation of Accountability Lab's SEFA required manual adjustments of Federal costs.
We noted that the manual adjustments were not completed prior to the start of the audit. We also
noted that a certain award was not clearly identified as Federal pass-through funds and therefore not
initially included on the SEFA. As a result, several adjustments were posted to the financial statements
to ensure Federal receivables, refundable advances and Federal revenue were properly recognized
and accurately stated at year-end.
Cause: The year-end close process did not provide for the preparation of a complete and accurate
schedule of expenditures of Federal awards.
Effect: Without periodic training and consistent application of Accountability Lab’s internal policies and
procedures, this could potentially result in unreliable and erroneous grant reporting, internal record
keeping and decision making.
Questioned Costs: None noted.
Context: Our audit testwork consisted of substantive procedures over the SEFA. We determined that
the issue was systemic in nature.
Identification as a Repeat Finding: Not applicable.
Recommendation: We recommend Accountability Lab establish internal controls to correctly identify
and track all Federal awards received either directly or indirectly.
Finding 2023-001: Preparation of Schedule of Expenditures of Federal Awards (SEFA)
Information on the Federal Programs: All
Criteria: As noted in 2 CFR 200.508 “Auditee Responsibilities” indicates that the auditee must prepare
appropriate financial statements, including the Schedule of Expenditures of Federal Awards (as
specifically defined under 2 CFR 200.510 “Financial statements”). Title 2 CFR 200 Section 200.510
“Financial Statements” requires recipients of Federal funds to 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. Additionally, in accordance with CFR 200.303, the non-
Federal entity must: 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.
Condition: Accountability Lab experienced difficulty in preparing and ensuring that all Federal
expenditures were identified, categorized, and included in the Schedule of Expenditures of Federal
Awards. The preparation of Accountability Lab's SEFA required manual adjustments of Federal costs.
We noted that the manual adjustments were not completed prior to the start of the audit. We also
noted that a certain award was not clearly identified as Federal pass-through funds and therefore not
initially included on the SEFA. As a result, several adjustments were posted to the financial statements
to ensure Federal receivables, refundable advances and Federal revenue were properly recognized
and accurately stated at year-end.
Cause: The year-end close process did not provide for the preparation of a complete and accurate
schedule of expenditures of Federal awards.
Effect: Without periodic training and consistent application of Accountability Lab’s internal policies and
procedures, this could potentially result in unreliable and erroneous grant reporting, internal record
keeping and decision making.
Questioned Costs: None noted.
Context: Our audit testwork consisted of substantive procedures over the SEFA. We determined that
the issue was systemic in nature.
Identification as a Repeat Finding: Not applicable.
Recommendation: We recommend Accountability Lab establish internal controls to correctly identify
and track all Federal awards received either directly or indirectly.
Finding 2023-001: Preparation of Schedule of Expenditures of Federal Awards (SEFA)
Information on the Federal Programs: All
Criteria: As noted in 2 CFR 200.508 “Auditee Responsibilities” indicates that the auditee must prepare
appropriate financial statements, including the Schedule of Expenditures of Federal Awards (as
specifically defined under 2 CFR 200.510 “Financial statements”). Title 2 CFR 200 Section 200.510
“Financial Statements” requires recipients of Federal funds to 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. Additionally, in accordance with CFR 200.303, the non-
Federal entity must: 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.
Condition: Accountability Lab experienced difficulty in preparing and ensuring that all Federal
expenditures were identified, categorized, and included in the Schedule of Expenditures of Federal
Awards. The preparation of Accountability Lab's SEFA required manual adjustments of Federal costs.
We noted that the manual adjustments were not completed prior to the start of the audit. We also
noted that a certain award was not clearly identified as Federal pass-through funds and therefore not
initially included on the SEFA. As a result, several adjustments were posted to the financial statements
to ensure Federal receivables, refundable advances and Federal revenue were properly recognized
and accurately stated at year-end.
Cause: The year-end close process did not provide for the preparation of a complete and accurate
schedule of expenditures of Federal awards.
Effect: Without periodic training and consistent application of Accountability Lab’s internal policies and
procedures, this could potentially result in unreliable and erroneous grant reporting, internal record
keeping and decision making.
Questioned Costs: None noted.
Context: Our audit testwork consisted of substantive procedures over the SEFA. We determined that
the issue was systemic in nature.
Identification as a Repeat Finding: Not applicable.
Recommendation: We recommend Accountability Lab establish internal controls to correctly identify
and track all Federal awards received either directly or indirectly.
Finding 2023-001: Preparation of Schedule of Expenditures of Federal Awards (SEFA)
Information on the Federal Programs: All
Criteria: As noted in 2 CFR 200.508 “Auditee Responsibilities” indicates that the auditee must prepare
appropriate financial statements, including the Schedule of Expenditures of Federal Awards (as
specifically defined under 2 CFR 200.510 “Financial statements”). Title 2 CFR 200 Section 200.510
“Financial Statements” requires recipients of Federal funds to 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. Additionally, in accordance with CFR 200.303, the non-
Federal entity must: 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.
Condition: Accountability Lab experienced difficulty in preparing and ensuring that all Federal
expenditures were identified, categorized, and included in the Schedule of Expenditures of Federal
Awards. The preparation of Accountability Lab's SEFA required manual adjustments of Federal costs.
We noted that the manual adjustments were not completed prior to the start of the audit. We also
noted that a certain award was not clearly identified as Federal pass-through funds and therefore not
initially included on the SEFA. As a result, several adjustments were posted to the financial statements
to ensure Federal receivables, refundable advances and Federal revenue were properly recognized
and accurately stated at year-end.
Cause: The year-end close process did not provide for the preparation of a complete and accurate
schedule of expenditures of Federal awards.
Effect: Without periodic training and consistent application of Accountability Lab’s internal policies and
procedures, this could potentially result in unreliable and erroneous grant reporting, internal record
keeping and decision making.
Questioned Costs: None noted.
Context: Our audit testwork consisted of substantive procedures over the SEFA. We determined that
the issue was systemic in nature.
Identification as a Repeat Finding: Not applicable.
Recommendation: We recommend Accountability Lab establish internal controls to correctly identify
and track all Federal awards received either directly or indirectly.
Finding 2023-002: Subrecipient Monitoring - Review of Audit Reports
Information on the Federal Program: Assistance Listing Numbers 19.705 and 19.345
Criteria: As stated in 2 CFR 200.332(f), all pass-through entities must verify that every subrecipient is
audited as required by 2 CFR 200 Subpart F when it is expected that the subrecipient's Federal awards
expended during the respective fiscal year equaled or exceeded the threshold for triggering such an
audit.
Condition: We were unable to determine whether Accountability Lab performed procedures to verify
whether or not its subrecipients were subject to a compliance audit in accordance with 2 CFR 200
Subpart F.
Cause: Accountability Lab does not have a formal/regularized process in place to monitor subrecipient
audit requirements.
Effect: Accountability Lab's current practices do not provide sufficient documentation to demonstrate
its compliance with the requirements to obtain and review subrecipient audit reports.
Questioned Costs: None noted.
Context: Our audit work included three subrecipients across two major programs. For two out of the
three subrecipients tested, we were not able to verify whether or not Accountability Lab obtained and
reviewed the subrecipient audit reports.
Identification as a Repeat Finding: Not applicable.
Recommendation: Accountability Lab should implement a "Review of Subrecipient Audit" form, to be
completed annually for each subrecipient that receives U.S. Government funding. The form should
document a) the subrecipient's name; b) the annual amount of U.S. Government funds expended by
the subrecipient; c) whether the subrecipient was subject to a U.S. Government compliance audit
under 2 CFR 200 Subpart F; and d) Accountability Lab's formal review of the audit report as well as its
conclusions and follow up on any reported findings, if applicable.
Finding 2023-001: Preparation of Schedule of Expenditures of Federal Awards (SEFA)
Information on the Federal Programs: All
Criteria: As noted in 2 CFR 200.508 “Auditee Responsibilities” indicates that the auditee must prepare
appropriate financial statements, including the Schedule of Expenditures of Federal Awards (as
specifically defined under 2 CFR 200.510 “Financial statements”). Title 2 CFR 200 Section 200.510
“Financial Statements” requires recipients of Federal funds to 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. Additionally, in accordance with CFR 200.303, the non-
Federal entity must: 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.
Condition: Accountability Lab experienced difficulty in preparing and ensuring that all Federal
expenditures were identified, categorized, and included in the Schedule of Expenditures of Federal
Awards. The preparation of Accountability Lab's SEFA required manual adjustments of Federal costs.
We noted that the manual adjustments were not completed prior to the start of the audit. We also
noted that a certain award was not clearly identified as Federal pass-through funds and therefore not
initially included on the SEFA. As a result, several adjustments were posted to the financial statements
to ensure Federal receivables, refundable advances and Federal revenue were properly recognized
and accurately stated at year-end.
Cause: The year-end close process did not provide for the preparation of a complete and accurate
schedule of expenditures of Federal awards.
Effect: Without periodic training and consistent application of Accountability Lab’s internal policies and
procedures, this could potentially result in unreliable and erroneous grant reporting, internal record
keeping and decision making.
Questioned Costs: None noted.
Context: Our audit testwork consisted of substantive procedures over the SEFA. We determined that
the issue was systemic in nature.
Identification as a Repeat Finding: Not applicable.
Recommendation: We recommend Accountability Lab establish internal controls to correctly identify
and track all Federal awards received either directly or indirectly.
Finding 2023-002: Subrecipient Monitoring - Review of Audit Reports
Information on the Federal Program: Assistance Listing Numbers 19.705 and 19.345
Criteria: As stated in 2 CFR 200.332(f), all pass-through entities must verify that every subrecipient is
audited as required by 2 CFR 200 Subpart F when it is expected that the subrecipient's Federal awards
expended during the respective fiscal year equaled or exceeded the threshold for triggering such an
audit.
Condition: We were unable to determine whether Accountability Lab performed procedures to verify
whether or not its subrecipients were subject to a compliance audit in accordance with 2 CFR 200
Subpart F.
Cause: Accountability Lab does not have a formal/regularized process in place to monitor subrecipient
audit requirements.
Effect: Accountability Lab's current practices do not provide sufficient documentation to demonstrate
its compliance with the requirements to obtain and review subrecipient audit reports.
Questioned Costs: None noted.
Context: Our audit work included three subrecipients across two major programs. For two out of the
three subrecipients tested, we were not able to verify whether or not Accountability Lab obtained and
reviewed the subrecipient audit reports.
Identification as a Repeat Finding: Not applicable.
Recommendation: Accountability Lab should implement a "Review of Subrecipient Audit" form, to be
completed annually for each subrecipient that receives U.S. Government funding. The form should
document a) the subrecipient's name; b) the annual amount of U.S. Government funds expended by
the subrecipient; c) whether the subrecipient was subject to a U.S. Government compliance audit
under 2 CFR 200 Subpart F; and d) Accountability Lab's formal review of the audit report as well as its
conclusions and follow up on any reported findings, if applicable.
Finding 2023-001: Preparation of Schedule of Expenditures of Federal Awards (SEFA)
Information on the Federal Programs: All
Criteria: As noted in 2 CFR 200.508 “Auditee Responsibilities” indicates that the auditee must prepare
appropriate financial statements, including the Schedule of Expenditures of Federal Awards (as
specifically defined under 2 CFR 200.510 “Financial statements”). Title 2 CFR 200 Section 200.510
“Financial Statements” requires recipients of Federal funds to 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. Additionally, in accordance with CFR 200.303, the non-
Federal entity must: 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.
Condition: Accountability Lab experienced difficulty in preparing and ensuring that all Federal
expenditures were identified, categorized, and included in the Schedule of Expenditures of Federal
Awards. The preparation of Accountability Lab's SEFA required manual adjustments of Federal costs.
We noted that the manual adjustments were not completed prior to the start of the audit. We also
noted that a certain award was not clearly identified as Federal pass-through funds and therefore not
initially included on the SEFA. As a result, several adjustments were posted to the financial statements
to ensure Federal receivables, refundable advances and Federal revenue were properly recognized
and accurately stated at year-end.
Cause: The year-end close process did not provide for the preparation of a complete and accurate
schedule of expenditures of Federal awards.
Effect: Without periodic training and consistent application of Accountability Lab’s internal policies and
procedures, this could potentially result in unreliable and erroneous grant reporting, internal record
keeping and decision making.
Questioned Costs: None noted.
Context: Our audit testwork consisted of substantive procedures over the SEFA. We determined that
the issue was systemic in nature.
Identification as a Repeat Finding: Not applicable.
Recommendation: We recommend Accountability Lab establish internal controls to correctly identify
and track all Federal awards received either directly or indirectly.
Finding 2023-001: Preparation of Schedule of Expenditures of Federal Awards (SEFA)
Information on the Federal Programs: All
Criteria: As noted in 2 CFR 200.508 “Auditee Responsibilities” indicates that the auditee must prepare
appropriate financial statements, including the Schedule of Expenditures of Federal Awards (as
specifically defined under 2 CFR 200.510 “Financial statements”). Title 2 CFR 200 Section 200.510
“Financial Statements” requires recipients of Federal funds to 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. Additionally, in accordance with CFR 200.303, the non-
Federal entity must: 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.
Condition: Accountability Lab experienced difficulty in preparing and ensuring that all Federal
expenditures were identified, categorized, and included in the Schedule of Expenditures of Federal
Awards. The preparation of Accountability Lab's SEFA required manual adjustments of Federal costs.
We noted that the manual adjustments were not completed prior to the start of the audit. We also
noted that a certain award was not clearly identified as Federal pass-through funds and therefore not
initially included on the SEFA. As a result, several adjustments were posted to the financial statements
to ensure Federal receivables, refundable advances and Federal revenue were properly recognized
and accurately stated at year-end.
Cause: The year-end close process did not provide for the preparation of a complete and accurate
schedule of expenditures of Federal awards.
Effect: Without periodic training and consistent application of Accountability Lab’s internal policies and
procedures, this could potentially result in unreliable and erroneous grant reporting, internal record
keeping and decision making.
Questioned Costs: None noted.
Context: Our audit testwork consisted of substantive procedures over the SEFA. We determined that
the issue was systemic in nature.
Identification as a Repeat Finding: Not applicable.
Recommendation: We recommend Accountability Lab establish internal controls to correctly identify
and track all Federal awards received either directly or indirectly.
Finding 2023-002: Subrecipient Monitoring - Review of Audit Reports
Information on the Federal Program: Assistance Listing Numbers 19.705 and 19.345
Criteria: As stated in 2 CFR 200.332(f), all pass-through entities must verify that every subrecipient is
audited as required by 2 CFR 200 Subpart F when it is expected that the subrecipient's Federal awards
expended during the respective fiscal year equaled or exceeded the threshold for triggering such an
audit.
Condition: We were unable to determine whether Accountability Lab performed procedures to verify
whether or not its subrecipients were subject to a compliance audit in accordance with 2 CFR 200
Subpart F.
Cause: Accountability Lab does not have a formal/regularized process in place to monitor subrecipient
audit requirements.
Effect: Accountability Lab's current practices do not provide sufficient documentation to demonstrate
its compliance with the requirements to obtain and review subrecipient audit reports.
Questioned Costs: None noted.
Context: Our audit work included three subrecipients across two major programs. For two out of the
three subrecipients tested, we were not able to verify whether or not Accountability Lab obtained and
reviewed the subrecipient audit reports.
Identification as a Repeat Finding: Not applicable.
Recommendation: Accountability Lab should implement a "Review of Subrecipient Audit" form, to be
completed annually for each subrecipient that receives U.S. Government funding. The form should
document a) the subrecipient's name; b) the annual amount of U.S. Government funds expended by
the subrecipient; c) whether the subrecipient was subject to a U.S. Government compliance audit
under 2 CFR 200 Subpart F; and d) Accountability Lab's formal review of the audit report as well as its
conclusions and follow up on any reported findings, if applicable.
Finding 2023-001: Preparation of Schedule of Expenditures of Federal Awards (SEFA)
Information on the Federal Programs: All
Criteria: As noted in 2 CFR 200.508 “Auditee Responsibilities” indicates that the auditee must prepare
appropriate financial statements, including the Schedule of Expenditures of Federal Awards (as
specifically defined under 2 CFR 200.510 “Financial statements”). Title 2 CFR 200 Section 200.510
“Financial Statements” requires recipients of Federal funds to 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. Additionally, in accordance with CFR 200.303, the non-
Federal entity must: 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.
Condition: Accountability Lab experienced difficulty in preparing and ensuring that all Federal
expenditures were identified, categorized, and included in the Schedule of Expenditures of Federal
Awards. The preparation of Accountability Lab's SEFA required manual adjustments of Federal costs.
We noted that the manual adjustments were not completed prior to the start of the audit. We also
noted that a certain award was not clearly identified as Federal pass-through funds and therefore not
initially included on the SEFA. As a result, several adjustments were posted to the financial statements
to ensure Federal receivables, refundable advances and Federal revenue were properly recognized
and accurately stated at year-end.
Cause: The year-end close process did not provide for the preparation of a complete and accurate
schedule of expenditures of Federal awards.
Effect: Without periodic training and consistent application of Accountability Lab’s internal policies and
procedures, this could potentially result in unreliable and erroneous grant reporting, internal record
keeping and decision making.
Questioned Costs: None noted.
Context: Our audit testwork consisted of substantive procedures over the SEFA. We determined that
the issue was systemic in nature.
Identification as a Repeat Finding: Not applicable.
Recommendation: We recommend Accountability Lab establish internal controls to correctly identify
and track all Federal awards received either directly or indirectly.