Audit 327351

FY End
2023-09-30
Total Expended
$20.61M
Findings
2
Programs
11
Organization: Disability Rights California (CA)
Year: 2023 Accepted: 2024-11-05
Auditor: Moss Adams LLP

Organization Exclusion Status:

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Contacts

Name Title Type
EUNQB6C9FBT4 Karen Keene Auditee
9165045800 Katherine Jackson Auditor
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Notes to SEFA

Title: Note 1 – Basis of Presentation Accounting Policies: Note 2 – Summary of Significant Accounting Policies Expenditures – Expenditures identifiable with specific programs are charged directly to the applicable program. Administrative personnel costs are allocated monthly based on the pro-rata share of the direct billable time for each grant/contract. Other shared costs (e.g., supplies, occupancy) are allocated to specific programs based upon the pro-rata share of the total number of programmatic staff working in each location and their full time equivalent for each grant/contract. Equipment – Equipment costing less than $5,000 is recorded as an expenditure of the applicable program when acquired. Property and equipment costing $5,000 or more is capitalized and depreciated using the straight-line method over estimated useful lives ranging from three to five years. Amounts Provided to Subrecipients – No federal awards were passed through to subrecipients during the year ended September 30, 2023. De Minimis Rate Used: Y Rate Explanation: The auditee used the de minimis cost rate. The accompanying schedule of expenditures of federal awards includes the federal grant activity of Disability Rights California (DRC) and is presented on the accrual basis of accounting. The information in the schedule of expenditures of federal awards is presented in accordance with requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the schedule of expenditures of federal awards presents only a selected portion of the operations of DRC, it is not intended to, and does not present the financial position, changes in net assets, or cash flows of DRC.
Title: Note 3 – Indirect Cost Rate Accounting Policies: Note 2 – Summary of Significant Accounting Policies Expenditures – Expenditures identifiable with specific programs are charged directly to the applicable program. Administrative personnel costs are allocated monthly based on the pro-rata share of the direct billable time for each grant/contract. Other shared costs (e.g., supplies, occupancy) are allocated to specific programs based upon the pro-rata share of the total number of programmatic staff working in each location and their full time equivalent for each grant/contract. Equipment – Equipment costing less than $5,000 is recorded as an expenditure of the applicable program when acquired. Property and equipment costing $5,000 or more is capitalized and depreciated using the straight-line method over estimated useful lives ranging from three to five years. Amounts Provided to Subrecipients – No federal awards were passed through to subrecipients during the year ended September 30, 2023. De Minimis Rate Used: Y Rate Explanation: The auditee used the de minimis cost rate. The Uniform Guidance requires that all indirect costs be charged through the use of an approved indirect cost rate. When no indirect cost rate has been approved, the Uniform Guidance allows for a one-time election to use a 10% de minimis reimbursement rate. DRC does not have an approved indirect cost rate and has elected to use the 10% de minimis reimbursement rate as allowed under Uniform Guidance.
Title: Note 4 – Restatement of Previously Issued Schedule of Expenditures of Federal Awards Accounting Policies: Note 2 – Summary of Significant Accounting Policies Expenditures – Expenditures identifiable with specific programs are charged directly to the applicable program. Administrative personnel costs are allocated monthly based on the pro-rata share of the direct billable time for each grant/contract. Other shared costs (e.g., supplies, occupancy) are allocated to specific programs based upon the pro-rata share of the total number of programmatic staff working in each location and their full time equivalent for each grant/contract. Equipment – Equipment costing less than $5,000 is recorded as an expenditure of the applicable program when acquired. Property and equipment costing $5,000 or more is capitalized and depreciated using the straight-line method over estimated useful lives ranging from three to five years. Amounts Provided to Subrecipients – No federal awards were passed through to subrecipients during the year ended September 30, 2023. De Minimis Rate Used: Y Rate Explanation: The auditee used the de minimis cost rate. The schedule of expenditures of federal awards for the year ended September 30, 2023, has been revised to include federal expenditures for Federal Assistance Listing Number 21.027 in the amount of $2,369,463. The total expenditures of federal awards was restated from $18,242,982 to $20,612,445.

Finding Details

FINDING 2023-001—Schedule of Expenditures of Federal Awards (SEFA) Material Weakness in Internal Control over Financial Reporting Material Weakness in Internal Control over Compliance—Reporting Federal agency – U.S. Department of Treasury Identification of federal program – Federal Assistance Listing No. 21.027, COVID-19 Coronavirus State and Local Fiscal Recovery Funds Award Number/Award Year – SLFRP3211 / 2022-2023 Criteria – Office of Management and Budget’s (OMB) Uniform Guidance requires the auditee to prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee's financial statements that includes total federal awards expended for each individual federal program, and that those programs be subject to timely audit. Condition – DRC improperly omitted the COVID-19 Coronavirus State and Local Fiscal Recovery Funds from its SEFA for the year ended September 30, 2023. Cause – DRC did not have adequate internal control to identify the federal funding that was passed through a state organization. Context – Restating the SEFA for the addition of the COVID-19 Coronavirus State and Local Fiscal Recovery Funds added expenditures totaling $2,369,463. The restated SEFA reports $20,612,445 in total federal expenditures. Effect – Uniform Guidance places the responsibility for identifying major programs on the auditor, and the SEFA serves as the primary basis for the auditor's major program determination. Appropriate major program determination by the auditor is dependent upon the accuracy and completeness of the information in the SEFA. The original SEFA was understated and incomplete as a result of the aforementioned program being improperly omitted. As a result, a major program was not properly identified and audited. Repeat Finding – Yes. Recommendation – We recommend that DRC update their grant agreement review procedures to ensure pass-through federal awards are properly identified and included in the SEFA. Response – See corrective action plan.
FINDING 2023-001—Schedule of Expenditures of Federal Awards (SEFA) Material Weakness in Internal Control over Financial Reporting Material Weakness in Internal Control over Compliance—Reporting Federal agency – U.S. Department of Treasury Identification of federal program – Federal Assistance Listing No. 21.027, COVID-19 Coronavirus State and Local Fiscal Recovery Funds Award Number/Award Year – SLFRP3211 / 2022-2023 Criteria – Office of Management and Budget’s (OMB) Uniform Guidance requires the auditee to prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee's financial statements that includes total federal awards expended for each individual federal program, and that those programs be subject to timely audit. Condition – DRC improperly omitted the COVID-19 Coronavirus State and Local Fiscal Recovery Funds from its SEFA for the year ended September 30, 2023. Cause – DRC did not have adequate internal control to identify the federal funding that was passed through a state organization. Context – Restating the SEFA for the addition of the COVID-19 Coronavirus State and Local Fiscal Recovery Funds added expenditures totaling $2,369,463. The restated SEFA reports $20,612,445 in total federal expenditures. Effect – Uniform Guidance places the responsibility for identifying major programs on the auditor, and the SEFA serves as the primary basis for the auditor's major program determination. Appropriate major program determination by the auditor is dependent upon the accuracy and completeness of the information in the SEFA. The original SEFA was understated and incomplete as a result of the aforementioned program being improperly omitted. As a result, a major program was not properly identified and audited. Repeat Finding – Yes. Recommendation – We recommend that DRC update their grant agreement review procedures to ensure pass-through federal awards are properly identified and included in the SEFA. Response – See corrective action plan.