FAC Explorer

Audit 351297

FY End
2024-06-30
Total Expended
$2.21M
Findings
2
Programs
2
Organization: Sociedad Para Asistencia Legal De Puerto Rico, Inc. (PR)
Year: 2024 Accepted: 2025-03-31
Auditor: Galindez LLC

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
546938 2024-001 - - L
1123380 2024-001 - - L

Programs

ALN Program Spent Major Findings
21.027 Coronavirus State and Local Fiscal Recovery Funds $2.16M Yes 1
16.738 Edward Byrne Memorial Justice Assistance Grant Program $47,532 - 0

Contacts

Name Title Type
FSPJASTR81J8 Héctor A. Díaz Pomales Auditee
7877653875 Taireli Hidalgo, Cpa, Fhfma Auditor
No contacts on file

Notes to SEFA

Title: Note 1 - Basis of presentation Accounting Policies: Summary of significant accounting policies a. The Schedule is prepared from the Organization’s accounting records. b. The financial transactions are recorded by the Organization in accordance with the terms and conditions of the grants, which are consistent with the accounting principles generally accepted in the United States of America. c. Expenditures are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. d. The Organization does not use the 10-percent de minimis indirect cost rate, as allowed under the Uniform Guidance De Minimis Rate Used: N Rate Explanation: Expenditures are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. The Organization does not use the 10-percent de minimis indirect cost rate, as allowed under the Uniform Guidance. The accompanying schedule of expenditures of federal awards (the Schedule) includes the federal grant activity of Sociedad para Asistencia Legal de Puerto Rico, Inc. (the Organization) under programs of the federal government for the year ended June 30, 2024. 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). Therefore, some amounts presented in this schedule may differ from amounts presented in, or used in the preparation of, the Organization’s financial statements. Because the Schedule presents only a selected portion of the operations of the Organization, it is not intended to and does not present the financial position, changes in net assets, or cash flows of the Organization.
Title: Note 2 - Summary of significant accounting policies Accounting Policies: Summary of significant accounting policies a. The Schedule is prepared from the Organization’s accounting records. b. The financial transactions are recorded by the Organization in accordance with the terms and conditions of the grants, which are consistent with the accounting principles generally accepted in the United States of America. c. Expenditures are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. d. The Organization does not use the 10-percent de minimis indirect cost rate, as allowed under the Uniform Guidance De Minimis Rate Used: N Rate Explanation: Expenditures are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. The Organization does not use the 10-percent de minimis indirect cost rate, as allowed under the Uniform Guidance. a. The Schedule is prepared from the Organization’s accounting records. b. The financial transactions are recorded by the Organization in accordance with the terms and conditions of the grants, which are consistent with the accounting principles generally accepted in the United States of America. c. Expenditures are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. d. The Organization does not use the 10-percent de minimis indirect cost rate, as allowed under the Uniform Guidance.
Title: Note 3 - Assistance listing number Accounting Policies: Summary of significant accounting policies a. The Schedule is prepared from the Organization’s accounting records. b. The financial transactions are recorded by the Organization in accordance with the terms and conditions of the grants, which are consistent with the accounting principles generally accepted in the United States of America. c. Expenditures are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. d. The Organization does not use the 10-percent de minimis indirect cost rate, as allowed under the Uniform Guidance De Minimis Rate Used: N Rate Explanation: Expenditures are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. The Organization does not use the 10-percent de minimis indirect cost rate, as allowed under the Uniform Guidance. The Assistance Listing Numbers (ALN) included in this Schedule are determined based on the program name, review of grant contract information and public descriptions of federal listings published by the U.S. Government on sam.gov. Assistance listing numbers are presented for those programs for which such numbers were available.
Title: Note 4 - Program costs Accounting Policies: Summary of significant accounting policies a. The Schedule is prepared from the Organization’s accounting records. b. The financial transactions are recorded by the Organization in accordance with the terms and conditions of the grants, which are consistent with the accounting principles generally accepted in the United States of America. c. Expenditures are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. d. The Organization does not use the 10-percent de minimis indirect cost rate, as allowed under the Uniform Guidance De Minimis Rate Used: N Rate Explanation: Expenditures are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. The Organization does not use the 10-percent de minimis indirect cost rate, as allowed under the Uniform Guidance. The amounts shown as federal expenditures represent only the federal grant portion of the program costs.

Finding Details

Finding 2024-001
Part III – Findings and Questioned Costs Relating to Federal Awards Finding No. 2024-001 – Bi-weekly Reporting Federal Program ALN 21.027 Coronavirus State and Local Fiscal Recovery Fund Name of Federal Agency U.S. Department of Treasury Pass-through Entity Puerto Rico Department of Treasury Category Internal Control/Compliance Compliance Requirement Reporting Criteria The resolution 2022-52 states the following: “WHEREAS, besides the compliance requirements of a federal award SAL must: (1) submit biweekly financial reports in which eligible use of funds is shown until the full expense is evidenced; (2) submit monthly reports in which evidence-based metrics demonstrate the effectiveness of the projects; and (3) include in a distribution agreement a provision that if the project fails to qualify for reimbursement because negligence or failure to meet applicable standards or requirements on the part of SAL, GPR has the option to recoup such funds from SAL.” In addition, as stated in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance), § 200.303 Internal controls, “the non-Federal entity must: (a) 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 or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal awards.” Condition During our reporting test, we detected reports that were submitted after the corresponding biweekly period. In addition, the expenditures in the reports contained errors of reporting related to the amounts for employee retentions for payroll taxes, which were included in the reports but are not expenditures incurred by the Organization. Cause Weak internal controls over the reporting process, including a lack of formalized oversight and monitoring mechanisms to ensure timely and accurate submission. Effect As a result of this condition, the grantor may issue warnings and/or impose penalties to the Organization. Also, the grantor was deprived of timely taking any action that it understood to be pertinent in the program. The analysis, evaluations, and decision-making of the grantee could be affected. Context Of a total of twenty-four (24) bi-weekly reports required for ALN 21.027, four (4) of the bi-weekly reports submitted were sent after their due date. In addition, all the reports sent to the oversight agency included the FICA and Medicare retention made the by Organization to employees participating on the program, which do not constitute expenditures made by the Organization. Resolution applicability Biweekly report due date Report Submission Date Days over due Date Res 2022-052, 2023-113 7/21/2023 7/28/2023 7 Res 2022-052, 2023-113 7/7/2023 7/14/2023 7 Res 2022-052, 2023-113 8/4/2023 8/11/2023 7 Res 2022-052, 2023-113 8/18/2023 8/25/2023 7 Identification of Repeat Finding This is not a repeat finding. Questioned Cost None. The FICA and Medicare retentions were wrongly reported on the bi-weekly reports but they were not claimed as federal expenditures by the Organization nor are included in the SEFA. Recommendation We strongly recommend the Organization to institute policies and procedures that stipulate the specific tasks and the personnel in charge of filing the required reports. Also, the policies and procedures should designate the member of management in charge of monitoring the compliance with the reporting requirements in order to make sure that the Organization is filing the reports by their respective due dates and with the correct amounts. It is critically important that timely and accurate reports be produced to ensure that the goals and purposes of the grant have been achieved and accounted for properly.
Finding 2024-001
Part III – Findings and Questioned Costs Relating to Federal Awards Finding No. 2024-001 – Bi-weekly Reporting Federal Program ALN 21.027 Coronavirus State and Local Fiscal Recovery Fund Name of Federal Agency U.S. Department of Treasury Pass-through Entity Puerto Rico Department of Treasury Category Internal Control/Compliance Compliance Requirement Reporting Criteria The resolution 2022-52 states the following: “WHEREAS, besides the compliance requirements of a federal award SAL must: (1) submit biweekly financial reports in which eligible use of funds is shown until the full expense is evidenced; (2) submit monthly reports in which evidence-based metrics demonstrate the effectiveness of the projects; and (3) include in a distribution agreement a provision that if the project fails to qualify for reimbursement because negligence or failure to meet applicable standards or requirements on the part of SAL, GPR has the option to recoup such funds from SAL.” In addition, as stated in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance), § 200.303 Internal controls, “the non-Federal entity must: (a) 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 or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal awards.” Condition During our reporting test, we detected reports that were submitted after the corresponding biweekly period. In addition, the expenditures in the reports contained errors of reporting related to the amounts for employee retentions for payroll taxes, which were included in the reports but are not expenditures incurred by the Organization. Cause Weak internal controls over the reporting process, including a lack of formalized oversight and monitoring mechanisms to ensure timely and accurate submission. Effect As a result of this condition, the grantor may issue warnings and/or impose penalties to the Organization. Also, the grantor was deprived of timely taking any action that it understood to be pertinent in the program. The analysis, evaluations, and decision-making of the grantee could be affected. Context Of a total of twenty-four (24) bi-weekly reports required for ALN 21.027, four (4) of the bi-weekly reports submitted were sent after their due date. In addition, all the reports sent to the oversight agency included the FICA and Medicare retention made the by Organization to employees participating on the program, which do not constitute expenditures made by the Organization. Resolution applicability Biweekly report due date Report Submission Date Days over due Date Res 2022-052, 2023-113 7/21/2023 7/28/2023 7 Res 2022-052, 2023-113 7/7/2023 7/14/2023 7 Res 2022-052, 2023-113 8/4/2023 8/11/2023 7 Res 2022-052, 2023-113 8/18/2023 8/25/2023 7 Identification of Repeat Finding This is not a repeat finding. Questioned Cost None. The FICA and Medicare retentions were wrongly reported on the bi-weekly reports but they were not claimed as federal expenditures by the Organization nor are included in the SEFA. Recommendation We strongly recommend the Organization to institute policies and procedures that stipulate the specific tasks and the personnel in charge of filing the required reports. Also, the policies and procedures should designate the member of management in charge of monitoring the compliance with the reporting requirements in order to make sure that the Organization is filing the reports by their respective due dates and with the correct amounts. It is critically important that timely and accurate reports be produced to ensure that the goals and purposes of the grant have been achieved and accounted for properly.