Finding 2023-001 Procurement
Information on the Federal Programs: 93.103
Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200, paragraph 318 “General
procurement standards” states that the non-Federal entity must use its own documented procurement
procedures which reflect applicable State, local, and tribal laws, and regulations, provided that the
procurements conform to applicable Federal law and the standards. Furthermore, paragraph 319
“Competition” states that all procurement transactions must be conducted in a manner providing full
and open competition consistent with these standards.
Condition: We noted instances where procurement procedures were not documented for purchases
in accordance with the Organization's threshold.
Cause: The Organization did not adhere to its procurement policy in that it failed to perform the
prescribed procurement procedures throughout the fiscal year.
Effect: Purchases of goods and services could be made above the prevailing market rates if the
prescribed procurement procedures are not adhered to, and thus, there lies the potential that the
Organization will not receive the best value for its purchases. The procurement process should also
allow for an evaluation of potential conflicts of interest with prospective vendors and contractors.
Furthermore, failure to perform the proper procurement procedures could result in disallowance of
Federal Expenditures based on lack of fair competition.
Questioned Costs: None noted.
Context: The Organization failed to adhere to its procurement policy, and hence, noncompliance with
Federal standards. Our audit work in this area consisted of internal control testwork over a random
sample of expenditures, as well as substantive testwork over transactions above a defined threshold
from select expense accounts that were charged to the Federal program. We consider our samples to
be representative of the respective populations, and thus, are statistically valid samples. The issue is
considered systemic in nature.
Identification as a Repeat Finding: Not applicable.
Recommendation: We recommend that the Organization ensure its policy is distributed and
communicated in a formal manner to its employees, and that management properly enforce
compliance with its policy. All procurement actions should be clearly documented in writing and
maintained in the vendor or contractor files.
Finding 2023-002 Year-End Closing Process
Information on the Federal Programs: All
Criteria: In accordance with 2 CFR 200.303, the Organization 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. 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: We had several current year audit adjustments including an adjustment to tie out opening
net assets, adjustments to update the year-end balance of investments, and additional audit
adjustments were provided late during the audit process that impacted the numbers on the Schedule
of Federal Expenditures. We will continue our prior year recommendation.
Cause: The monthly and year-end closing process did not detect these corrections.
Effect: If all accounts are not properly reconciled as of year-end, the Organization's consolidated
financial statements may contain undetected misstatements.
Questioned Costs: None noted.
Context: Our audit included testwork over significant asset and liability balances.
Identification as a Repeat Finding: See Finding 2022-001
Recommendation: We recommend that the Organization pay additional attention to the closing
process to ensure that all accounts are reconciled in advance of the audit. Review and approval
procedures should be in place to ensure that errors are detected.
Finding 2023-002 Year-End Closing Process
Information on the Federal Programs: All
Criteria: In accordance with 2 CFR 200.303, the Organization 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. 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: We had several current year audit adjustments including an adjustment to tie out opening
net assets, adjustments to update the year-end balance of investments, and additional audit
adjustments were provided late during the audit process that impacted the numbers on the Schedule
of Federal Expenditures. We will continue our prior year recommendation.
Cause: The monthly and year-end closing process did not detect these corrections.
Effect: If all accounts are not properly reconciled as of year-end, the Organization's consolidated
financial statements may contain undetected misstatements.
Questioned Costs: None noted.
Context: Our audit included testwork over significant asset and liability balances.
Identification as a Repeat Finding: See Finding 2022-001
Recommendation: We recommend that the Organization pay additional attention to the closing
process to ensure that all accounts are reconciled in advance of the audit. Review and approval
procedures should be in place to ensure that errors are detected.
Finding 2023-001 Procurement
Information on the Federal Programs: 93.103
Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200, paragraph 318 “General
procurement standards” states that the non-Federal entity must use its own documented procurement
procedures which reflect applicable State, local, and tribal laws, and regulations, provided that the
procurements conform to applicable Federal law and the standards. Furthermore, paragraph 319
“Competition” states that all procurement transactions must be conducted in a manner providing full
and open competition consistent with these standards.
Condition: We noted instances where procurement procedures were not documented for purchases
in accordance with the Organization's threshold.
Cause: The Organization did not adhere to its procurement policy in that it failed to perform the
prescribed procurement procedures throughout the fiscal year.
Effect: Purchases of goods and services could be made above the prevailing market rates if the
prescribed procurement procedures are not adhered to, and thus, there lies the potential that the
Organization will not receive the best value for its purchases. The procurement process should also
allow for an evaluation of potential conflicts of interest with prospective vendors and contractors.
Furthermore, failure to perform the proper procurement procedures could result in disallowance of
Federal Expenditures based on lack of fair competition.
Questioned Costs: None noted.
Context: The Organization failed to adhere to its procurement policy, and hence, noncompliance with
Federal standards. Our audit work in this area consisted of internal control testwork over a random
sample of expenditures, as well as substantive testwork over transactions above a defined threshold
from select expense accounts that were charged to the Federal program. We consider our samples to
be representative of the respective populations, and thus, are statistically valid samples. The issue is
considered systemic in nature.
Identification as a Repeat Finding: Not applicable.
Recommendation: We recommend that the Organization ensure its policy is distributed and
communicated in a formal manner to its employees, and that management properly enforce
compliance with its policy. All procurement actions should be clearly documented in writing and
maintained in the vendor or contractor files.
Finding 2023-002 Year-End Closing Process
Information on the Federal Programs: All
Criteria: In accordance with 2 CFR 200.303, the Organization 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. 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: We had several current year audit adjustments including an adjustment to tie out opening
net assets, adjustments to update the year-end balance of investments, and additional audit
adjustments were provided late during the audit process that impacted the numbers on the Schedule
of Federal Expenditures. We will continue our prior year recommendation.
Cause: The monthly and year-end closing process did not detect these corrections.
Effect: If all accounts are not properly reconciled as of year-end, the Organization's consolidated
financial statements may contain undetected misstatements.
Questioned Costs: None noted.
Context: Our audit included testwork over significant asset and liability balances.
Identification as a Repeat Finding: See Finding 2022-001
Recommendation: We recommend that the Organization pay additional attention to the closing
process to ensure that all accounts are reconciled in advance of the audit. Review and approval
procedures should be in place to ensure that errors are detected.
Finding 2023-002 Year-End Closing Process
Information on the Federal Programs: All
Criteria: In accordance with 2 CFR 200.303, the Organization 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. 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: We had several current year audit adjustments including an adjustment to tie out opening
net assets, adjustments to update the year-end balance of investments, and additional audit
adjustments were provided late during the audit process that impacted the numbers on the Schedule
of Federal Expenditures. We will continue our prior year recommendation.
Cause: The monthly and year-end closing process did not detect these corrections.
Effect: If all accounts are not properly reconciled as of year-end, the Organization's consolidated
financial statements may contain undetected misstatements.
Questioned Costs: None noted.
Context: Our audit included testwork over significant asset and liability balances.
Identification as a Repeat Finding: See Finding 2022-001
Recommendation: We recommend that the Organization pay additional attention to the closing
process to ensure that all accounts are reconciled in advance of the audit. Review and approval
procedures should be in place to ensure that errors are detected.