FAC Explorer

Audit 348713

FY End
2024-06-30
Total Expended
$4.79M
Findings
2
Programs
3
Organization: National Association of Criminal Defence Lawyers, Inc. (DC)
Year: 2024 Accepted: 2025-03-26
Auditor: Gelman Rosenberg & Freedman

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
537482 2024-001 Significant Deficiency - M
1113924 2024-001 Significant Deficiency - M

Programs

ALN Program Spent Major Findings
16.738 Edward Byrne Memorial Justice Assistance Grant Program $2.50M Yes 1
16.582 Crime Victim Assistance/discretionary Grants $94,875 - 0
16.827 Justice Reinvestment Initiative $93,236 - 0

Contacts

Name Title Type
DHMDHLCSJWY5 Hugene Fields Auditee
2025258217 Walt Derengowski Auditor
No contacts on file

Notes to SEFA

Title: Note 1. Basis of Presentation Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. De Minimis Rate Used: N Rate Explanation: Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the Schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. The Association has elected not to use the de minimis indirect cost rate as allowed under the Uniform Guidance. The accompanying Schedule of Expenditures of Federal Awards (the Schedule) includes the Federal award activity of the Association under programs of the Federal Government for the year ended June 30, 2024. Information in the Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). The Schedule presents only a selected portion of the operations of the Association; accordingly, it is not intended to and does not present the financial position, changes in net assets or cash flows of the Association.
Title: Note 2. Summary of Significant Accounting Policies Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. De Minimis Rate Used: N Rate Explanation: Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the Schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. The Association has elected not to use the de minimis indirect cost rate as allowed under the Uniform Guidance. Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the Schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. The Association has elected not to use the de minimis indirect cost rate as allowed under the Uniform Guidance.

Finding Details

Finding 2024-001
Finding: 2024-001 Subrecipient Monitoring Information on the Federal Program: Assistance Listing Number 16.738 Criteria: CFR § 200.332, "Requirements for pass-through entities", requires pass-through entities to evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. Condition: As part of our audit, we selected a sample of subawards charged to the major Federal program. We noted that the pre-award risk assessments were not performed until November 2024, subsequent to the subawards being signed with the subawardees. Based on our discussions with management, the process for performing pre-award risk assessments for subrecipients and determining and documenting the appropriate level of ongoing monitoring for subrecipients was implemented in November 2024. Cause: The Association did not perform pre-award risk assessments on its subrecipients as required by Federal regulation. Effect: The Association could inadvertently engage in relationships with subrecipients of higher risk without the appropriate level of oversight (i.e. monitoring) to ensure subrecipients are expending funds in accordance with the provisions and terms of the subaward. Questioned Costs: None noted. Context: Our audit procedures in this area consisted of substantive testwork over a sample of subrecipient expenditures that were selected based on a defined threshold. We consider our sample to be representative of the populations, and thus, is a statistically valid sample. The issue is deemed to be systemic. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Association strictly adhere to its current subaward policy and ensure the risk assessment procedures over all of its subrecipients are performed and documented prior to engagement. Based on these risk assessments, the Association should assign a risk level to each, and then determine the monitoring tools to apply based on these risk levels.
Finding 2024-001
Finding: 2024-001 Subrecipient Monitoring Information on the Federal Program: Assistance Listing Number 16.738 Criteria: CFR § 200.332, "Requirements for pass-through entities", requires pass-through entities to evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. Condition: As part of our audit, we selected a sample of subawards charged to the major Federal program. We noted that the pre-award risk assessments were not performed until November 2024, subsequent to the subawards being signed with the subawardees. Based on our discussions with management, the process for performing pre-award risk assessments for subrecipients and determining and documenting the appropriate level of ongoing monitoring for subrecipients was implemented in November 2024. Cause: The Association did not perform pre-award risk assessments on its subrecipients as required by Federal regulation. Effect: The Association could inadvertently engage in relationships with subrecipients of higher risk without the appropriate level of oversight (i.e. monitoring) to ensure subrecipients are expending funds in accordance with the provisions and terms of the subaward. Questioned Costs: None noted. Context: Our audit procedures in this area consisted of substantive testwork over a sample of subrecipient expenditures that were selected based on a defined threshold. We consider our sample to be representative of the populations, and thus, is a statistically valid sample. The issue is deemed to be systemic. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Association strictly adhere to its current subaward policy and ensure the risk assessment procedures over all of its subrecipients are performed and documented prior to engagement. Based on these risk assessments, the Association should assign a risk level to each, and then determine the monitoring tools to apply based on these risk levels.