FAC Explorer

Audit 334631

FY End
2022-12-31
Total Expended
$1.29M
Findings
8
Programs
2
Organization: California Asian Pacific Chamber of Commerce (CA)
Year: 2022 Accepted: 2024-12-23
Auditor: Richardson & Company LLP

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
516654 2022-001 Material Weakness - L
516655 2022-002 Material Weakness - I
516656 2022-003 Material Weakness - A
516657 2022-004 Significant Deficiency - A
1093096 2022-001 Material Weakness - L
1093097 2022-002 Material Weakness - I
1093098 2022-003 Material Weakness - A
1093099 2022-004 Significant Deficiency - A

Programs

ALN Program Spent Major Findings
11.802 Minority Business Resource Development $457,771 Yes 0
20.910 Assistance to Small and Disadvantaged Businesses $62,344 - 0

Contacts

Name Title Type
REKPMJDM1C78 Ryan Fong Auditee
9164467883 Ingrid Sheipline Auditor
No contacts on file

Notes to SEFA

Title: BASIS OF PRESENTATION Accounting Policies: Expenses reported on the Schedule are reported on the accrual basis of accounting. Such expenses are recognized following the cost principles contained in the Uniform Guidance and/or OMB Circular A-122, Cost Principles for Non-Profit Organizations, wherein certain types of expenses are not allowable or are limited as to reimbursement. De Minimis Rate Used: Y Rate Explanation: The Chamber has elected to use the 10% de minimis indirect cost rate under the Uniform Guidance. The accompanying schedule of expenditures of federal awards includes the federal grant activity of the Chamber under programs of the federal government for the year ended December 31, 2022. The information in this schedule is presented in accordance with the 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 presents only a selected portion of the Chamber’s operations, it is not intended to be and does not present the financial position, changes in net position, or cash flows of the Chamber.
Title: SUBRECIPIENTS Accounting Policies: Expenses reported on the Schedule are reported on the accrual basis of accounting. Such expenses are recognized following the cost principles contained in the Uniform Guidance and/or OMB Circular A-122, Cost Principles for Non-Profit Organizations, wherein certain types of expenses are not allowable or are limited as to reimbursement. De Minimis Rate Used: Y Rate Explanation: The Chamber has elected to use the 10% de minimis indirect cost rate under the Uniform Guidance. There were no subrecipients of the Chamber’s programs during the year ended December 31, 2022.
Title: PROGRAM COSTS/MATCHING CONTRIBUTIONS Accounting Policies: Expenses reported on the Schedule are reported on the accrual basis of accounting. Such expenses are recognized following the cost principles contained in the Uniform Guidance and/or OMB Circular A-122, Cost Principles for Non-Profit Organizations, wherein certain types of expenses are not allowable or are limited as to reimbursement. De Minimis Rate Used: Y Rate Explanation: The Chamber has elected to use the 10% de minimis indirect cost rate under the Uniform Guidance. The amounts shown as current year expenses represent only the federal grant portion of the program costs. Entire program costs, including the Chamber’s portion, may be more than shown.
Title: NONCASH AWARDS Accounting Policies: Expenses reported on the Schedule are reported on the accrual basis of accounting. Such expenses are recognized following the cost principles contained in the Uniform Guidance and/or OMB Circular A-122, Cost Principles for Non-Profit Organizations, wherein certain types of expenses are not allowable or are limited as to reimbursement. De Minimis Rate Used: Y Rate Explanation: The Chamber has elected to use the 10% de minimis indirect cost rate under the Uniform Guidance. No noncash awards existed in the current year.

Finding Details

Finding 2022-001
Finding 2022-001: Material Weakness - Untimely Audit Submission in Accordance with OMB Uniform Guidance Federal Grantor: All Federal Programs Compliance Requirement: Reporting Condition: The Chamber did not electronically submit their December 31, 2022 Single Audit reporting package (Single Audit Report, Data Collection Form, Status of Prior Year Findings, and a Corrective Action Plan) within the required time period. Criteria: The Chamber was required to submit its December 31, 2022 audited financial statements and single audit reporting package to the federal audit clearinghouse no later than September 30, 2023, 9 months after the fiscal year-end (2 Code of Federal Regulations 200.512(a)). Effect: Federal awarding agencies may deny the Chamber future federal awards or subject the Chamber to additional monitoring requirements. Cause: The Chamber was not able to complete its single audit by the reporting deadline due to staff shortages. Recommendation: We recommended that management strengthen the related internal controls over monitoring of its year-end reconciliation of its financial statements to ensure that the general ledger accounts reflect proper and complete activity consistent with their basis of accounting. We believe that reviews, evaluations of transactions, and reconciliations of accounts should be performed on a regular basis during the year. This would expedite the year-end closing process and ensure compliance with the audit report submission requirements of OMB Uniform Guidance. Views of Responsible Officials and Planned Corrective Actions: The Chamber agrees with the finding and is in the process of implementing processes to ensure timely close-out of the books.
Finding 2022-002
Finding 2022-002: Material Weakness – Lack of Documentation on Sole Source Contracts and Verification of Vendors Federal grantor: Department of Commerce Condition: The Chamber contract with a vendor on a sole-source basis and did not document justification for the use of a sole source vendor. In addition, the Chamber did not verify that the vendor was not on the list of vendors suspended or debarred from federal contracting before contracting with the vendor. Criteria: Entities are required to follow the procurement standards in 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320 and noncompetitive procurements. Entities also must comply with 2 CFR Part 1326 that prohibits entities that have been debarred, suspended or voluntarily excluded from participating in Federal procurement. Cause: The Chamber’s Procurement Policy allows for a sole source vendor but requires staff to document sole source procurements prior to initial purchase. It appears staff did not follow its policy. The Policy also contains a requirement to verify or receive vendor certification that they are not debarred, suspended, ineligible or voluntarily excluded from Federal procurements, but this procedure was not followed. Effect: The Department of Commerce may impose additional conditions on the receipt of a subsequent tranche of future award funds, if any, or take other available remedies as set forth in 2 C.F.C. section 200.339. Recommendation: We recommend the Chamber review policies with staff to ensure procurement requirements are followed, and that staff are familiar with federal procurement requirements. Views of Responsible Officials and Planned Corrective Actions: The Chamber agrees with this finding and is in the process of implementing changes to their procurement process.
Finding 2022-003
Finding 2022-003: Material Weakness and Questioned Cost – Grant Claim Support Federal grantor: Department of Commerce Condition: The Chamber’s expenditure detail for the grant funded projects do not support the amounts billed to the Department of Commerce. The amounts billed were more than the general ledger detail supported. Criteria: A reconciliation of grant project expenses to the grant revenue billed should be performed. The supporting documentation of any reconciling items should be maintained with the grant bills. Also, 2 CFR 200.400 states that accounting practices of the entity be consistent with cost principals required under the CFR and support the accumulation of costs and provide adequate documentation to support costs charged to the Federal award. Cause: The Chamber billed costs to the grant that were not allocated in the accounting system to that grant and a reconciliation was not performed comparing the grant billings to the expense detail. Effect: The expenses billed to the grant may not be correct. Our reconciliation of these expenses disclosed an overbilling to the grant of approximately $2,500 in 2021. Recommendation: The Chamber needs to ensure that expenses to be reimbursed by federal grant funds are recorded in the class code in the accounting system for that grant so that federal grant revenue in the accounting system match the expenses allocated to that grant. The Chamber needs to include in their year-end reconciliations a comparison of grant revenue and expense and ensure they match or can be reconciled. Views of Responsible Officials and Planned Corrective Actions: The Chamber agrees with this finding and is in the process of implementing a system for improved grant tracking.
Finding 2022-004
Finding 2022-004: Significant Deficiency – Grant Claim Support Federal grantor: Department of Commerce Condition: The allocation of payroll costs to programs are done manually using spreadsheets instead of done based on entity-wide timesheets. Criteria: Under 2 CFR 200.400, direct cost allocation principles state that if a cost benefits two or more projects or activities in proportions that can be determined without undue effort or cost, the cost must be allocated to the projects based on the proportional benefit. If a cost benefits two or more projects or activities in proportions that cannot be determined because of the interrelationship of the work involved, then the costs may be allocated or transferred to benefitted projects on any reasonable documented basis. Further, a cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. Costs are required to be adequately documented. Cause: The Chamber is not able to readily determine the amount of payroll costs billable to the grants. Effect: The approach of manually allocating payroll costs to grant projects leaves room for error, and makes it difficult to determine that costs are not being reimbursed by more than one source. Recommendation: The Chamber needs to prepare time studies or require employees to prepare timesheets on an automated system to support the payroll costs allocated to programs. Views of Responsible Officials and Planned Corrective Actions: The Chamber agrees with the finding and is in the process of implementing a better time and expense tracking system that will be effective in 2024.
Finding 2022-001
Finding 2022-001: Material Weakness - Untimely Audit Submission in Accordance with OMB Uniform Guidance Federal Grantor: All Federal Programs Compliance Requirement: Reporting Condition: The Chamber did not electronically submit their December 31, 2022 Single Audit reporting package (Single Audit Report, Data Collection Form, Status of Prior Year Findings, and a Corrective Action Plan) within the required time period. Criteria: The Chamber was required to submit its December 31, 2022 audited financial statements and single audit reporting package to the federal audit clearinghouse no later than September 30, 2023, 9 months after the fiscal year-end (2 Code of Federal Regulations 200.512(a)). Effect: Federal awarding agencies may deny the Chamber future federal awards or subject the Chamber to additional monitoring requirements. Cause: The Chamber was not able to complete its single audit by the reporting deadline due to staff shortages. Recommendation: We recommended that management strengthen the related internal controls over monitoring of its year-end reconciliation of its financial statements to ensure that the general ledger accounts reflect proper and complete activity consistent with their basis of accounting. We believe that reviews, evaluations of transactions, and reconciliations of accounts should be performed on a regular basis during the year. This would expedite the year-end closing process and ensure compliance with the audit report submission requirements of OMB Uniform Guidance. Views of Responsible Officials and Planned Corrective Actions: The Chamber agrees with the finding and is in the process of implementing processes to ensure timely close-out of the books.
Finding 2022-002
Finding 2022-002: Material Weakness – Lack of Documentation on Sole Source Contracts and Verification of Vendors Federal grantor: Department of Commerce Condition: The Chamber contract with a vendor on a sole-source basis and did not document justification for the use of a sole source vendor. In addition, the Chamber did not verify that the vendor was not on the list of vendors suspended or debarred from federal contracting before contracting with the vendor. Criteria: Entities are required to follow the procurement standards in 2 CFR sections 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320 and noncompetitive procurements. Entities also must comply with 2 CFR Part 1326 that prohibits entities that have been debarred, suspended or voluntarily excluded from participating in Federal procurement. Cause: The Chamber’s Procurement Policy allows for a sole source vendor but requires staff to document sole source procurements prior to initial purchase. It appears staff did not follow its policy. The Policy also contains a requirement to verify or receive vendor certification that they are not debarred, suspended, ineligible or voluntarily excluded from Federal procurements, but this procedure was not followed. Effect: The Department of Commerce may impose additional conditions on the receipt of a subsequent tranche of future award funds, if any, or take other available remedies as set forth in 2 C.F.C. section 200.339. Recommendation: We recommend the Chamber review policies with staff to ensure procurement requirements are followed, and that staff are familiar with federal procurement requirements. Views of Responsible Officials and Planned Corrective Actions: The Chamber agrees with this finding and is in the process of implementing changes to their procurement process.
Finding 2022-003
Finding 2022-003: Material Weakness and Questioned Cost – Grant Claim Support Federal grantor: Department of Commerce Condition: The Chamber’s expenditure detail for the grant funded projects do not support the amounts billed to the Department of Commerce. The amounts billed were more than the general ledger detail supported. Criteria: A reconciliation of grant project expenses to the grant revenue billed should be performed. The supporting documentation of any reconciling items should be maintained with the grant bills. Also, 2 CFR 200.400 states that accounting practices of the entity be consistent with cost principals required under the CFR and support the accumulation of costs and provide adequate documentation to support costs charged to the Federal award. Cause: The Chamber billed costs to the grant that were not allocated in the accounting system to that grant and a reconciliation was not performed comparing the grant billings to the expense detail. Effect: The expenses billed to the grant may not be correct. Our reconciliation of these expenses disclosed an overbilling to the grant of approximately $2,500 in 2021. Recommendation: The Chamber needs to ensure that expenses to be reimbursed by federal grant funds are recorded in the class code in the accounting system for that grant so that federal grant revenue in the accounting system match the expenses allocated to that grant. The Chamber needs to include in their year-end reconciliations a comparison of grant revenue and expense and ensure they match or can be reconciled. Views of Responsible Officials and Planned Corrective Actions: The Chamber agrees with this finding and is in the process of implementing a system for improved grant tracking.
Finding 2022-004
Finding 2022-004: Significant Deficiency – Grant Claim Support Federal grantor: Department of Commerce Condition: The allocation of payroll costs to programs are done manually using spreadsheets instead of done based on entity-wide timesheets. Criteria: Under 2 CFR 200.400, direct cost allocation principles state that if a cost benefits two or more projects or activities in proportions that can be determined without undue effort or cost, the cost must be allocated to the projects based on the proportional benefit. If a cost benefits two or more projects or activities in proportions that cannot be determined because of the interrelationship of the work involved, then the costs may be allocated or transferred to benefitted projects on any reasonable documented basis. Further, a cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. Costs are required to be adequately documented. Cause: The Chamber is not able to readily determine the amount of payroll costs billable to the grants. Effect: The approach of manually allocating payroll costs to grant projects leaves room for error, and makes it difficult to determine that costs are not being reimbursed by more than one source. Recommendation: The Chamber needs to prepare time studies or require employees to prepare timesheets on an automated system to support the payroll costs allocated to programs. Views of Responsible Officials and Planned Corrective Actions: The Chamber agrees with the finding and is in the process of implementing a better time and expense tracking system that will be effective in 2024.