2023-001 Twenty-First Century Community Learning Centers – Assistance Listing No. 84.287
Significant Deficiency in Internal Control Over Compliance and Noncompliance – Appropriate Internal
Control Structure Related to Compliance Requirements
A. Activities Allowed or Unallowed, B. Allowable Costs/Cost Principles, and C. Cash Management
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 Organization does not have the written policies in place in accordance with §200.302
Financial Management paragraph (b)(6) and (b)(7), which requires written procedures for determining the
allowability of costs in accordance with Subpart E of the Uniform Guidance and the terms and conditions of the
federal award.
Cause and Effect: As the policies referenced above are not written, the Organization is not in compliance with the
requirements. In addition, lack of written policies related to federal awards may lead to noncompliance with other
federal requirements and the terms and conditions of federal awards.
Recommendation: We recommend the policies in accordance with §200.302 Financial Management paragraph
(b)(6) and (b)(7) be written by the Organization, approved by the Board of Directors, and included in the
permanent files of BGCH.
Views of Responsible Officials and Planned Corrective Action: We agree with the recommendation and plan to
have the corrective action implemented by December 31, 2024. Boys & Girls Club of Huntington has always
followed the Twenty-First Century Community Learning Centers policy on activities allowed or unallowed, but had
not put a written policy in place to recognize this, so will create the written policy and have it approved by the end
of 2024.
2023-002 Twenty-First Century Community Learning Centers – Assistance Listing No. 84.287
Significant Deficiency in Internal Control Over Compliance – Appropriate Monitoring of Levels of Federal
Funding
Criteria: 2 CFR §200.501 Audit Requirements, establishes that a non-Federal entity that expends $750,000 or
more during the non-Federal entity's fiscal year in Federal awards must have a single or program-specific audit
conducted for that year in accordance with the provisions of the Uniform Guidance.
Condition and Context: The Organization did not have procedures in place to timely identify that federal
expenditures for the year ended December 31, 2023, exceeded $750,000 and that an audit in accordance with
the provisions of Uniform Guidance was required. However, an audit firm was ultimately engaged to perform the
applicable audit prior to the deadline for submission. Cause and Effect: The deficiency in internal control over compliance could lead to the failure to comply with audit
requirements under the Uniform Guidance.
Recommendation: The Organization should implement policies and procedures to periodically monitor federal
funding and expenditure levels throughout the year to ensure a level of awareness regarding whether an audit
under the Uniform Guidance may be applicable for the current year. In addition, the Organization should prepare
a schedule of federal expenditures (SEFA) as part of its year-end closing process, which reconciles to the general
ledger. The SEFA and data used to prepare the SEFA should be reviewed by a separate individual within the
Organization with knowledge of the related reporting requirements, as outlined in the Uniform Guidance, to
ensure its accuracy and completeness. The schedule should be used to determine whether an audit in
accordance with the provisions of the Uniform Guidance is required so that an auditor may be engaged to perform
a timely audit.
Views of Responsible Officials and Planned Corrective Action: We agree with the recommendation and plan to
have the corrective action implemented by December 31, 2024. Boys & Girls Club of Huntington Finance Board
Subcommitee discusses this item throughout the fiscal year and is in the Board minutes, but has not put a written
policy in place. A policy will be created by the Finance Board Subcommittee at the October meeting, presented to
the full Board or Directors at the November Board meeting and voted on at the December 2024 Board meeting.
2023-003 Twenty-First Century Community Learning Centers – Assistance Listing No. 84.287
Material Weakness in Internal Control Over Compliance and Noncompliance – A. Activities Allowed or
Unallowed and B. Allowable Costs/Cost Principles
Criteria: 2 CFR 200.430(i) indicates costs must be based on records that accurately reflect the work performed to
be considered allowable. These records must be supported by a system of internal control which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated.
Condition and Context: We selected a sample of 25 instances of time allocated to the grant. We noted 20
instances where time allocated to the grant which lacked formal review of the time allocated. We noted 1
instance of time allocated which lacked adequate documentation resulting in questioned costs of $689. We
identified likely questioned costs of $20,367 based on applying an error rate of 4.71% from our sample. Our
sample was not statistically valid.
Cause and Effect: Policies and procedures were inconsistently applied to personnel costs, resulting in questioned
costs.
Recommendation: We recommend that the Organization establish a formal documentation process to ensure
personnel costs are adequately documented, reviewed, and allocated to the federal award.
Views of Responsible Officials and Planned Corrective Action: We agree with the recommendation and plan to
have corrective action implemented by December 31, 2024. An updated timesheet policy with the correct wording
will be created by the Finance Board Subcommitee at the October meeting, presented to the full Board of
Directors at the November Board meeting and voted on at the December 2024 Board meeting.
2023-001 Twenty-First Century Community Learning Centers – Assistance Listing No. 84.287
Significant Deficiency in Internal Control Over Compliance and Noncompliance – Appropriate Internal
Control Structure Related to Compliance Requirements
A. Activities Allowed or Unallowed, B. Allowable Costs/Cost Principles, and C. Cash Management
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 Organization does not have the written policies in place in accordance with §200.302
Financial Management paragraph (b)(6) and (b)(7), which requires written procedures for determining the
allowability of costs in accordance with Subpart E of the Uniform Guidance and the terms and conditions of the
federal award.
Cause and Effect: As the policies referenced above are not written, the Organization is not in compliance with the
requirements. In addition, lack of written policies related to federal awards may lead to noncompliance with other
federal requirements and the terms and conditions of federal awards.
Recommendation: We recommend the policies in accordance with §200.302 Financial Management paragraph
(b)(6) and (b)(7) be written by the Organization, approved by the Board of Directors, and included in the
permanent files of BGCH.
Views of Responsible Officials and Planned Corrective Action: We agree with the recommendation and plan to
have the corrective action implemented by December 31, 2024. Boys & Girls Club of Huntington has always
followed the Twenty-First Century Community Learning Centers policy on activities allowed or unallowed, but had
not put a written policy in place to recognize this, so will create the written policy and have it approved by the end
of 2024.
2023-002 Twenty-First Century Community Learning Centers – Assistance Listing No. 84.287
Significant Deficiency in Internal Control Over Compliance – Appropriate Monitoring of Levels of Federal
Funding
Criteria: 2 CFR §200.501 Audit Requirements, establishes that a non-Federal entity that expends $750,000 or
more during the non-Federal entity's fiscal year in Federal awards must have a single or program-specific audit
conducted for that year in accordance with the provisions of the Uniform Guidance.
Condition and Context: The Organization did not have procedures in place to timely identify that federal
expenditures for the year ended December 31, 2023, exceeded $750,000 and that an audit in accordance with
the provisions of Uniform Guidance was required. However, an audit firm was ultimately engaged to perform the
applicable audit prior to the deadline for submission. Cause and Effect: The deficiency in internal control over compliance could lead to the failure to comply with audit
requirements under the Uniform Guidance.
Recommendation: The Organization should implement policies and procedures to periodically monitor federal
funding and expenditure levels throughout the year to ensure a level of awareness regarding whether an audit
under the Uniform Guidance may be applicable for the current year. In addition, the Organization should prepare
a schedule of federal expenditures (SEFA) as part of its year-end closing process, which reconciles to the general
ledger. The SEFA and data used to prepare the SEFA should be reviewed by a separate individual within the
Organization with knowledge of the related reporting requirements, as outlined in the Uniform Guidance, to
ensure its accuracy and completeness. The schedule should be used to determine whether an audit in
accordance with the provisions of the Uniform Guidance is required so that an auditor may be engaged to perform
a timely audit.
Views of Responsible Officials and Planned Corrective Action: We agree with the recommendation and plan to
have the corrective action implemented by December 31, 2024. Boys & Girls Club of Huntington Finance Board
Subcommitee discusses this item throughout the fiscal year and is in the Board minutes, but has not put a written
policy in place. A policy will be created by the Finance Board Subcommittee at the October meeting, presented to
the full Board or Directors at the November Board meeting and voted on at the December 2024 Board meeting.
2023-003 Twenty-First Century Community Learning Centers – Assistance Listing No. 84.287
Material Weakness in Internal Control Over Compliance and Noncompliance – A. Activities Allowed or
Unallowed and B. Allowable Costs/Cost Principles
Criteria: 2 CFR 200.430(i) indicates costs must be based on records that accurately reflect the work performed to
be considered allowable. These records must be supported by a system of internal control which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated.
Condition and Context: We selected a sample of 25 instances of time allocated to the grant. We noted 20
instances where time allocated to the grant which lacked formal review of the time allocated. We noted 1
instance of time allocated which lacked adequate documentation resulting in questioned costs of $689. We
identified likely questioned costs of $20,367 based on applying an error rate of 4.71% from our sample. Our
sample was not statistically valid.
Cause and Effect: Policies and procedures were inconsistently applied to personnel costs, resulting in questioned
costs.
Recommendation: We recommend that the Organization establish a formal documentation process to ensure
personnel costs are adequately documented, reviewed, and allocated to the federal award.
Views of Responsible Officials and Planned Corrective Action: We agree with the recommendation and plan to
have corrective action implemented by December 31, 2024. An updated timesheet policy with the correct wording
will be created by the Finance Board Subcommitee at the October meeting, presented to the full Board of
Directors at the November Board meeting and voted on at the December 2024 Board meeting.