2023-002 ALLOWABILITY
Federal Program Information: Federal Agency and Program Name Federal Assistance Listing Number
National Endowment for the Humanities
Promotion of the Humanities Federal/State Partnership
Grant Number: SO-289836-23 45.129
Criteria:
2 CFR 200.303 requires that a non-federal entity must “(a) 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 and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
For two of the 40 transactions selected for testing, there was no documentation of review and approval of the expenditure for allowability and payment.
Questioned Costs:
None
Context:
Total federal expenditures for the Promotion of the Humanities Federal/State Partnership program were $1,019,055 for the year ended October 31, 2023.
Cause:
Internal controls were not operating effectively to ensure the allowability of expenditures.
Effect:
Expenditures could be made that are not allowable.
Identification as a Repeat Finding:
Prior Year Finding 2022-002
Recommendation:
We recommend that the Council implement controls to ensure that expenditures are properly reviewed and approved before being charged to a federal award.
Views of Responsible Officials:
Management acknowledges the finding. See corrective action plan.
2023-003 REPORTING
Federal Program Information: Federal Agency and Program Name Federal Assistance Listing Number
National Endowment for the Humanities
Promotion of the Humanities Federal/State Partnership
Grant Number: SO-289836-23 45.129
Criteria:
2 CFR 200.303 requires that a non-federal entity must “(a) 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 and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
2 CFR 200.302(b) states that “the financial management system of each non-Federal entity must provide for… accurate, current, and complete disclosure of the financial results of each Federal award or program…”
Condition:
For both of the SF-425 reports selected for testing, there was no documentation of review and approval of the SF-425 report prior to submission. For one of the SF-425 reports selected for testing, inaccurate data was input and submitted.
Questioned Costs:
None
Context:
Total federal expenditures for the Promotion of the Humanities Federal/State Partnership program were $1,019,055 for the year ended October 31, 2023.
Cause:
The Council does not have adequate internal controls and policies and procedures in place to ensure that reports contain accurate financial information and are reviewed before submission.
Effect:
The Council is not reporting accurate financial information to its federal grantor.
Identification as a Repeat Finding:
This is not a repeat finding from the prior year.
Recommendation:
We recommend that the Council implement controls and policies and procedures over financial reporting to ensure compliance with federal reporting requirements.
Views of Responsible Officials:
Management acknowledges the finding. See corrective action plan.
2023-004 SEFA REPORTING
Federal Program Information: Federal Agency and Program Name Federal Assistance Listing Number
National Endowment for the Humanities
Promotion of the Humanities Federal/State Partnership
Grant Number: SO-289836-23 45.129
Criteria:
2 CFR 200.303 requires that a non-federal entity must “(a) 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 and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
2 CFR 200.510(b) states that “the auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR 200.502.”
Condition:
The Council’s internal controls are not adequate to ensure the Schedule of Expenditures of Federal Awards (SEFA) accurately reports Federal assistance. The Council’s fiscal year 2023 SEFA for the Promotion of the Humanities Federal/State Partnership program included expenditures from other fiscal years.
Questioned Costs:
$4,015
Context:
Total federal expenditures for the Promotion of the Humanities Federal/State Partnership program were $1,019,055 for the year ended October 31, 2023.
Cause:
The Council does not have adequate internal controls in place to ensure the accuracy of the SEFA.
Effect:
The Council is not reporting accurate financial information in its SEFA.
Identification as a Repeat Finding:
This is not a repeat finding from the prior year.
Recommendation:
We recommend that the Council implement controls over financial reporting, including the SEFA, to ensure accuracy of financial data.
Views of Responsible Officials:
Management acknowledges the finding. See corrective action plan.
2023-002 ALLOWABILITY
Federal Program Information: Federal Agency and Program Name Federal Assistance Listing Number
National Endowment for the Humanities
Promotion of the Humanities Federal/State Partnership
Grant Number: SO-289836-23 45.129
Criteria:
2 CFR 200.303 requires that a non-federal entity must “(a) 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 and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
For two of the 40 transactions selected for testing, there was no documentation of review and approval of the expenditure for allowability and payment.
Questioned Costs:
None
Context:
Total federal expenditures for the Promotion of the Humanities Federal/State Partnership program were $1,019,055 for the year ended October 31, 2023.
Cause:
Internal controls were not operating effectively to ensure the allowability of expenditures.
Effect:
Expenditures could be made that are not allowable.
Identification as a Repeat Finding:
Prior Year Finding 2022-002
Recommendation:
We recommend that the Council implement controls to ensure that expenditures are properly reviewed and approved before being charged to a federal award.
Views of Responsible Officials:
Management acknowledges the finding. See corrective action plan.
2023-003 REPORTING
Federal Program Information: Federal Agency and Program Name Federal Assistance Listing Number
National Endowment for the Humanities
Promotion of the Humanities Federal/State Partnership
Grant Number: SO-289836-23 45.129
Criteria:
2 CFR 200.303 requires that a non-federal entity must “(a) 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 and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
2 CFR 200.302(b) states that “the financial management system of each non-Federal entity must provide for… accurate, current, and complete disclosure of the financial results of each Federal award or program…”
Condition:
For both of the SF-425 reports selected for testing, there was no documentation of review and approval of the SF-425 report prior to submission. For one of the SF-425 reports selected for testing, inaccurate data was input and submitted.
Questioned Costs:
None
Context:
Total federal expenditures for the Promotion of the Humanities Federal/State Partnership program were $1,019,055 for the year ended October 31, 2023.
Cause:
The Council does not have adequate internal controls and policies and procedures in place to ensure that reports contain accurate financial information and are reviewed before submission.
Effect:
The Council is not reporting accurate financial information to its federal grantor.
Identification as a Repeat Finding:
This is not a repeat finding from the prior year.
Recommendation:
We recommend that the Council implement controls and policies and procedures over financial reporting to ensure compliance with federal reporting requirements.
Views of Responsible Officials:
Management acknowledges the finding. See corrective action plan.
2023-004 SEFA REPORTING
Federal Program Information: Federal Agency and Program Name Federal Assistance Listing Number
National Endowment for the Humanities
Promotion of the Humanities Federal/State Partnership
Grant Number: SO-289836-23 45.129
Criteria:
2 CFR 200.303 requires that a non-federal entity must “(a) 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 and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
2 CFR 200.510(b) states that “the auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR 200.502.”
Condition:
The Council’s internal controls are not adequate to ensure the Schedule of Expenditures of Federal Awards (SEFA) accurately reports Federal assistance. The Council’s fiscal year 2023 SEFA for the Promotion of the Humanities Federal/State Partnership program included expenditures from other fiscal years.
Questioned Costs:
$4,015
Context:
Total federal expenditures for the Promotion of the Humanities Federal/State Partnership program were $1,019,055 for the year ended October 31, 2023.
Cause:
The Council does not have adequate internal controls in place to ensure the accuracy of the SEFA.
Effect:
The Council is not reporting accurate financial information in its SEFA.
Identification as a Repeat Finding:
This is not a repeat finding from the prior year.
Recommendation:
We recommend that the Council implement controls over financial reporting, including the SEFA, to ensure accuracy of financial data.
Views of Responsible Officials:
Management acknowledges the finding. See corrective action plan.