Federal Agency: Department of Justice
Federal Program Name: Services for Victims of Human Trafficking
Assistance Listing Number: 16.320
Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003,
15POVC-21-GG-03694-HT (2021), and 2020-HT-OVC-614
Award Period: October 1, 2020 through September 30, 2024
Type of Finding:
• Material Weakness in Internal Control over Compliance
Criteria or specific requirement: The Organization is required to submit quarterly financial reports and semi-annual performance reports to the Federal Agency.
Condition: The Organization did not have controls in place to prevent, detect, or correct errors in reporting.
Questioned costs: None
Context: During our testing, it was noted that there was no formal layer of review over the required reports prepared before it was submitted to the Federal Agency. The financial information submitted was not supported as records were not retained.
Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff.
Effect or potential effect: The financial information reported to the Federal Agency could be materially misstated.
Repeat Finding: No
Recommendation: We recommend the Organization design controls to ensure reports are prepared and reviewed by separate individuals and that the information gathered to prepare the report is retained.
Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the report and before submission to the Federal Agency and will make sure support gathered is retained.
Federal Agency: Department of Justice
Federal Program Name: Services for Victims of Human Trafficking
Assistance Listing Number: 16.320
Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003,
15POVC-21-GG-03694-HT (2021), and 2020-HT-OVC-614
Award Period: October 1, 2020 through September 30, 2024
Type of Finding:
• Material Weakness in Internal Control over Compliance
Criteria or specific requirement: The Organization is required to submit quarterly financial reports and semi-annual performance reports to the Federal Agency.
Condition: The Organization did not have controls in place to prevent, detect, or correct errors in reporting.
Questioned costs: None
Context: During our testing, it was noted that there was no formal layer of review over the required reports prepared before it was submitted to the Federal Agency. The financial information submitted was not supported as records were not retained.
Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff.
Effect or potential effect: The financial information reported to the Federal Agency could be materially misstated.
Repeat Finding: No
Recommendation: We recommend the Organization design controls to ensure reports are prepared and reviewed by separate individuals and that the information gathered to prepare the report is retained.
Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the report and before submission to the Federal Agency and will make sure support gathered is retained.
Federal Agency: Department of Justice
Federal Program Name: Services for Victims of Human Trafficking
Assistance Listing Number: 16.320
Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003,
15POVC-21-GG-03694-HT (2021), and 2020-HT-OVC-614
Award Period: October 1, 2020 through September 30, 2024
Type of Finding:
• Material Weakness in Internal Control over Compliance
Criteria or specific requirement: The Organization is required to submit quarterly financial reports and semi-annual performance reports to the Federal Agency.
Condition: The Organization did not have controls in place to prevent, detect, or correct errors in reporting.
Questioned costs: None
Context: During our testing, it was noted that there was no formal layer of review over the required reports prepared before it was submitted to the Federal Agency. The financial information submitted was not supported as records were not retained.
Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff.
Effect or potential effect: The financial information reported to the Federal Agency could be materially misstated.
Repeat Finding: No
Recommendation: We recommend the Organization design controls to ensure reports are prepared and reviewed by separate individuals and that the information gathered to prepare the report is retained.
Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the report and before submission to the Federal Agency and will make sure support gathered is retained.
Federal Agency: Department of Justice
Federal Program Name: Services for Victims of Human Trafficking
Assistance Listing Number: 16.320
Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003,
15POVC-21-GG-03694-HT (2021), and 2020-HT-OVC-614
Award Period: October 1, 2020 through September 30, 2024
Type of Finding:
• Material Weakness in Internal Control over Compliance
Criteria or specific requirement: The Organization is required to submit quarterly financial reports and semi-annual performance reports to the Federal Agency.
Condition: The Organization did not have controls in place to prevent, detect, or correct errors in reporting.
Questioned costs: None
Context: During our testing, it was noted that there was no formal layer of review over the required reports prepared before it was submitted to the Federal Agency. The financial information submitted was not supported as records were not retained.
Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff.
Effect or potential effect: The financial information reported to the Federal Agency could be materially misstated.
Repeat Finding: No
Recommendation: We recommend the Organization design controls to ensure reports are prepared and reviewed by separate individuals and that the information gathered to prepare the report is retained.
Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the report and before submission to the Federal Agency and will make sure support gathered is retained.
Federal Agency: Department of Justice
Federal Program Name: Services for Victims of Human Trafficking
Assistance Listing Number: 16.320
Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003,
15POVC-21-GG-03694-HT (2021), and 2020-HT-OVC-614
Award Period: October 1, 2020 through September 30, 2024
Type of Finding:
• Material Weakness in Internal Control over Compliance
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of cash management. The Organization should have internal controls designed to ensure compliance with those provisions.
Condition: During our testing, we noted the Organization did not have adequate internal controls designed to ensure requests for reimbursement were supported by costs incurred and paid within 30 days.
Questioned costs: None
Context: During our testing, it was noted that there was no formal layer of review over the draw down requests prepared by the accountant before it was submitted to the awarding agency. Amounts drawn did not consistently agree to known upcoming or previously incurred expenditures.
Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff.
Effect or potential effect: The auditor noted no instances of noncompliance with the provisions of cash management; however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance that could be material.
Repeat Finding: No
Recommendation: We recommend the Organization design controls to ensure the draw down requests and related support are formally reviewed and approved by the Executive Director before submitting the request to the awarding agency and that the support is retained.
Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the draw down request and support and before submission to the awarding agency and make sure the approved support is kept on file.
Federal Agency: Department of Justice
Federal Program Name: Services for Victims of Human Trafficking
Assistance Listing Number: 16.320
Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003,
15POVC-21-GG-03694-HT (2021), and 2020-HT-OVC-614
Award Period: October 1, 2020 through September 30, 2024
Type of Finding:
• Material Weakness in Internal Control over Compliance
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of cash management. The Organization should have internal controls designed to ensure compliance with those provisions.
Condition: During our testing, we noted the Organization did not have adequate internal controls designed to ensure requests for reimbursement were supported by costs incurred and paid within 30 days.
Questioned costs: None
Context: During our testing, it was noted that there was no formal layer of review over the draw down requests prepared by the accountant before it was submitted to the awarding agency. Amounts drawn did not consistently agree to known upcoming or previously incurred expenditures.
Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff.
Effect or potential effect: The auditor noted no instances of noncompliance with the provisions of cash management; however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance that could be material.
Repeat Finding: No
Recommendation: We recommend the Organization design controls to ensure the draw down requests and related support are formally reviewed and approved by the Executive Director before submitting the request to the awarding agency and that the support is retained.
Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the draw down request and support and before submission to the awarding agency and make sure the approved support is kept on file.
Federal Agency: Department of Justice
Federal Program Name: Services for Victims of Human Trafficking
Assistance Listing Number: 16.320
Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003,
15POVC-21-GG-03694-HT (2021), and 2020-HT-OVC-614
Award Period: October 1, 2020 through September 30, 2024
Type of Finding:
• Material Weakness in Internal Control over Compliance
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of cash management. The Organization should have internal controls designed to ensure compliance with those provisions.
Condition: During our testing, we noted the Organization did not have adequate internal controls designed to ensure requests for reimbursement were supported by costs incurred and paid within 30 days.
Questioned costs: None
Context: During our testing, it was noted that there was no formal layer of review over the draw down requests prepared by the accountant before it was submitted to the awarding agency. Amounts drawn did not consistently agree to known upcoming or previously incurred expenditures.
Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff.
Effect or potential effect: The auditor noted no instances of noncompliance with the provisions of cash management; however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance that could be material.
Repeat Finding: No
Recommendation: We recommend the Organization design controls to ensure the draw down requests and related support are formally reviewed and approved by the Executive Director before submitting the request to the awarding agency and that the support is retained.
Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the draw down request and support and before submission to the awarding agency and make sure the approved support is kept on file.
Federal Agency: Department of Justice
Federal Program Name: Services for Victims of Human Trafficking
Assistance Listing Number: 16.320
Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003,
15POVC-21-GG-03694-HT (2021), and 2020-HT-OVC-614
Award Period: October 1, 2020 through September 30, 2024
Type of Finding:
• Material Weakness in Internal Control over Compliance
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of cash management. The Organization should have internal controls designed to ensure compliance with those provisions.
Condition: During our testing, we noted the Organization did not have adequate internal controls designed to ensure requests for reimbursement were supported by costs incurred and paid within 30 days.
Questioned costs: None
Context: During our testing, it was noted that there was no formal layer of review over the draw down requests prepared by the accountant before it was submitted to the awarding agency. Amounts drawn did not consistently agree to known upcoming or previously incurred expenditures.
Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff.
Effect or potential effect: The auditor noted no instances of noncompliance with the provisions of cash management; however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance that could be material.
Repeat Finding: No
Recommendation: We recommend the Organization design controls to ensure the draw down requests and related support are formally reviewed and approved by the Executive Director before submitting the request to the awarding agency and that the support is retained.
Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the draw down request and support and before submission to the awarding agency and make sure the approved support is kept on file.
Federal Agency: Department of Justice
Federal Program Name: Services for Victims of Human Trafficking
Assistance Listing Number: 16.320
Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003,
15POVC-21-GG-03694-HT (2021), and 2020-HT-OVC-614
Award Period: October 1, 2020 through September 30, 2024
Type of Finding:
• Material Weakness in Internal Control over Compliance
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of allowable costs. The Organization should have internal controls designed to ensure compliance with those provisions.
Condition: Internal controls over compliance for allowable costs were not in place to support that the Organization was requesting reimbursement for costs allowable by the Federal Agency.
Questioned costs: None as the net impact of the two errors identified below are $0.
Context:
Indirect Allocations
In a sample of 8, 5 drawdown requests were submitted to the Federal Agency at a lower cost rate than the 10 percent de minimis threshold allowed for by the Federal Agency. 1 of the 8 was submitted at a higher rate than the 10 percent de minimis threshold. The net impact of the inconsistency of the rate being applied to each draw within our sample resulted in the Organization charging $2,115 less to the grant than earned.
Cash Disbursements (other than payroll related items)
In a sample of 7, 1 of the items included as an allowable cost was an error. The expense of $2,115 was incurred by the Organization but incorrectly posted in their accounting software. The support of the disbursement received supported that the cost was not allowable per the grant guidelines.
Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff.
Effect or potential effect: The amounts reimbursed by the Federal Agency may by unallowable and result in a refund to the Federal Agency.
Repeat Finding: No
Recommendation: We recommend the Organization design controls to ensure the draw down requests and related support are formally reviewed and approved by the Executive Director for allowability before submitting the request to the awarding agency.
Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the draw down request and support and before submission to the awarding agency and make sure the approved support is kept on file.
Federal Agency: Department of Justice
Federal Program Name: Services for Victims of Human Trafficking
Assistance Listing Number: 16.320
Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003,
15POVC-21-GG-03694-HT (2021), and 2020-HT-OVC-614
Award Period: October 1, 2020 through September 30, 2024
Type of Finding:
• Material Weakness in Internal Control over Compliance
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of allowable costs. The Organization should have internal controls designed to ensure compliance with those provisions.
Condition: Internal controls over compliance for allowable costs were not in place to support that the Organization was requesting reimbursement for costs allowable by the Federal Agency.
Questioned costs: None as the net impact of the two errors identified below are $0.
Context:
Indirect Allocations
In a sample of 8, 5 drawdown requests were submitted to the Federal Agency at a lower cost rate than the 10 percent de minimis threshold allowed for by the Federal Agency. 1 of the 8 was submitted at a higher rate than the 10 percent de minimis threshold. The net impact of the inconsistency of the rate being applied to each draw within our sample resulted in the Organization charging $2,115 less to the grant than earned.
Cash Disbursements (other than payroll related items)
In a sample of 7, 1 of the items included as an allowable cost was an error. The expense of $2,115 was incurred by the Organization but incorrectly posted in their accounting software. The support of the disbursement received supported that the cost was not allowable per the grant guidelines.
Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff.
Effect or potential effect: The amounts reimbursed by the Federal Agency may by unallowable and result in a refund to the Federal Agency.
Repeat Finding: No
Recommendation: We recommend the Organization design controls to ensure the draw down requests and related support are formally reviewed and approved by the Executive Director for allowability before submitting the request to the awarding agency.
Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the draw down request and support and before submission to the awarding agency and make sure the approved support is kept on file.
Federal Agency: Department of Justice
Federal Program Name: Services for Victims of Human Trafficking
Assistance Listing Number: 16.320
Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003,
15POVC-21-GG-03694-HT (2021), and 2020-HT-OVC-614
Award Period: October 1, 2020 through September 30, 2024
Type of Finding:
• Material Weakness in Internal Control over Compliance
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of allowable costs. The Organization should have internal controls designed to ensure compliance with those provisions.
Condition: Internal controls over compliance for allowable costs were not in place to support that the Organization was requesting reimbursement for costs allowable by the Federal Agency.
Questioned costs: None as the net impact of the two errors identified below are $0.
Context:
Indirect Allocations
In a sample of 8, 5 drawdown requests were submitted to the Federal Agency at a lower cost rate than the 10 percent de minimis threshold allowed for by the Federal Agency. 1 of the 8 was submitted at a higher rate than the 10 percent de minimis threshold. The net impact of the inconsistency of the rate being applied to each draw within our sample resulted in the Organization charging $2,115 less to the grant than earned.
Cash Disbursements (other than payroll related items)
In a sample of 7, 1 of the items included as an allowable cost was an error. The expense of $2,115 was incurred by the Organization but incorrectly posted in their accounting software. The support of the disbursement received supported that the cost was not allowable per the grant guidelines.
Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff.
Effect or potential effect: The amounts reimbursed by the Federal Agency may by unallowable and result in a refund to the Federal Agency.
Repeat Finding: No
Recommendation: We recommend the Organization design controls to ensure the draw down requests and related support are formally reviewed and approved by the Executive Director for allowability before submitting the request to the awarding agency.
Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the draw down request and support and before submission to the awarding agency and make sure the approved support is kept on file.
Federal Agency: Department of Justice
Federal Program Name: Services for Victims of Human Trafficking
Assistance Listing Number: 16.320
Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003,
15POVC-21-GG-03694-HT (2021), and 2020-HT-OVC-614
Award Period: October 1, 2020 through September 30, 2024
Type of Finding:
• Material Weakness in Internal Control over Compliance
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of allowable costs. The Organization should have internal controls designed to ensure compliance with those provisions.
Condition: Internal controls over compliance for allowable costs were not in place to support that the Organization was requesting reimbursement for costs allowable by the Federal Agency.
Questioned costs: None as the net impact of the two errors identified below are $0.
Context:
Indirect Allocations
In a sample of 8, 5 drawdown requests were submitted to the Federal Agency at a lower cost rate than the 10 percent de minimis threshold allowed for by the Federal Agency. 1 of the 8 was submitted at a higher rate than the 10 percent de minimis threshold. The net impact of the inconsistency of the rate being applied to each draw within our sample resulted in the Organization charging $2,115 less to the grant than earned.
Cash Disbursements (other than payroll related items)
In a sample of 7, 1 of the items included as an allowable cost was an error. The expense of $2,115 was incurred by the Organization but incorrectly posted in their accounting software. The support of the disbursement received supported that the cost was not allowable per the grant guidelines.
Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff.
Effect or potential effect: The amounts reimbursed by the Federal Agency may by unallowable and result in a refund to the Federal Agency.
Repeat Finding: No
Recommendation: We recommend the Organization design controls to ensure the draw down requests and related support are formally reviewed and approved by the Executive Director for allowability before submitting the request to the awarding agency.
Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the draw down request and support and before submission to the awarding agency and make sure the approved support is kept on file.
Federal Agency: Department of Justice
Federal Program Name: Services for Victims of Human Trafficking
Assistance Listing Number: 16.320
Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003,
15POVC-21-GG-03694-HT (2021), and 2020-HT-OVC-614
Award Period: October 1, 2020 through September 30, 2024
Type of Finding:
• Material Weakness in Internal Control over Compliance
Criteria or specific requirement: The Organization is required to submit quarterly financial reports and semi-annual performance reports to the Federal Agency.
Condition: The Organization did not have controls in place to prevent, detect, or correct errors in reporting.
Questioned costs: None
Context: During our testing, it was noted that there was no formal layer of review over the required reports prepared before it was submitted to the Federal Agency. The financial information submitted was not supported as records were not retained.
Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff.
Effect or potential effect: The financial information reported to the Federal Agency could be materially misstated.
Repeat Finding: No
Recommendation: We recommend the Organization design controls to ensure reports are prepared and reviewed by separate individuals and that the information gathered to prepare the report is retained.
Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the report and before submission to the Federal Agency and will make sure support gathered is retained.
Federal Agency: Department of Justice
Federal Program Name: Services for Victims of Human Trafficking
Assistance Listing Number: 16.320
Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003,
15POVC-21-GG-03694-HT (2021), and 2020-HT-OVC-614
Award Period: October 1, 2020 through September 30, 2024
Type of Finding:
• Material Weakness in Internal Control over Compliance
Criteria or specific requirement: The Organization is required to submit quarterly financial reports and semi-annual performance reports to the Federal Agency.
Condition: The Organization did not have controls in place to prevent, detect, or correct errors in reporting.
Questioned costs: None
Context: During our testing, it was noted that there was no formal layer of review over the required reports prepared before it was submitted to the Federal Agency. The financial information submitted was not supported as records were not retained.
Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff.
Effect or potential effect: The financial information reported to the Federal Agency could be materially misstated.
Repeat Finding: No
Recommendation: We recommend the Organization design controls to ensure reports are prepared and reviewed by separate individuals and that the information gathered to prepare the report is retained.
Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the report and before submission to the Federal Agency and will make sure support gathered is retained.
Federal Agency: Department of Justice
Federal Program Name: Services for Victims of Human Trafficking
Assistance Listing Number: 16.320
Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003,
15POVC-21-GG-03694-HT (2021), and 2020-HT-OVC-614
Award Period: October 1, 2020 through September 30, 2024
Type of Finding:
• Material Weakness in Internal Control over Compliance
Criteria or specific requirement: The Organization is required to submit quarterly financial reports and semi-annual performance reports to the Federal Agency.
Condition: The Organization did not have controls in place to prevent, detect, or correct errors in reporting.
Questioned costs: None
Context: During our testing, it was noted that there was no formal layer of review over the required reports prepared before it was submitted to the Federal Agency. The financial information submitted was not supported as records were not retained.
Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff.
Effect or potential effect: The financial information reported to the Federal Agency could be materially misstated.
Repeat Finding: No
Recommendation: We recommend the Organization design controls to ensure reports are prepared and reviewed by separate individuals and that the information gathered to prepare the report is retained.
Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the report and before submission to the Federal Agency and will make sure support gathered is retained.
Federal Agency: Department of Justice
Federal Program Name: Services for Victims of Human Trafficking
Assistance Listing Number: 16.320
Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003,
15POVC-21-GG-03694-HT (2021), and 2020-HT-OVC-614
Award Period: October 1, 2020 through September 30, 2024
Type of Finding:
• Material Weakness in Internal Control over Compliance
Criteria or specific requirement: The Organization is required to submit quarterly financial reports and semi-annual performance reports to the Federal Agency.
Condition: The Organization did not have controls in place to prevent, detect, or correct errors in reporting.
Questioned costs: None
Context: During our testing, it was noted that there was no formal layer of review over the required reports prepared before it was submitted to the Federal Agency. The financial information submitted was not supported as records were not retained.
Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff.
Effect or potential effect: The financial information reported to the Federal Agency could be materially misstated.
Repeat Finding: No
Recommendation: We recommend the Organization design controls to ensure reports are prepared and reviewed by separate individuals and that the information gathered to prepare the report is retained.
Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the report and before submission to the Federal Agency and will make sure support gathered is retained.
Federal Agency: Department of Justice
Federal Program Name: Services for Victims of Human Trafficking
Assistance Listing Number: 16.320
Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003,
15POVC-21-GG-03694-HT (2021), and 2020-HT-OVC-614
Award Period: October 1, 2020 through September 30, 2024
Type of Finding:
• Material Weakness in Internal Control over Compliance
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of cash management. The Organization should have internal controls designed to ensure compliance with those provisions.
Condition: During our testing, we noted the Organization did not have adequate internal controls designed to ensure requests for reimbursement were supported by costs incurred and paid within 30 days.
Questioned costs: None
Context: During our testing, it was noted that there was no formal layer of review over the draw down requests prepared by the accountant before it was submitted to the awarding agency. Amounts drawn did not consistently agree to known upcoming or previously incurred expenditures.
Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff.
Effect or potential effect: The auditor noted no instances of noncompliance with the provisions of cash management; however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance that could be material.
Repeat Finding: No
Recommendation: We recommend the Organization design controls to ensure the draw down requests and related support are formally reviewed and approved by the Executive Director before submitting the request to the awarding agency and that the support is retained.
Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the draw down request and support and before submission to the awarding agency and make sure the approved support is kept on file.
Federal Agency: Department of Justice
Federal Program Name: Services for Victims of Human Trafficking
Assistance Listing Number: 16.320
Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003,
15POVC-21-GG-03694-HT (2021), and 2020-HT-OVC-614
Award Period: October 1, 2020 through September 30, 2024
Type of Finding:
• Material Weakness in Internal Control over Compliance
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of cash management. The Organization should have internal controls designed to ensure compliance with those provisions.
Condition: During our testing, we noted the Organization did not have adequate internal controls designed to ensure requests for reimbursement were supported by costs incurred and paid within 30 days.
Questioned costs: None
Context: During our testing, it was noted that there was no formal layer of review over the draw down requests prepared by the accountant before it was submitted to the awarding agency. Amounts drawn did not consistently agree to known upcoming or previously incurred expenditures.
Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff.
Effect or potential effect: The auditor noted no instances of noncompliance with the provisions of cash management; however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance that could be material.
Repeat Finding: No
Recommendation: We recommend the Organization design controls to ensure the draw down requests and related support are formally reviewed and approved by the Executive Director before submitting the request to the awarding agency and that the support is retained.
Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the draw down request and support and before submission to the awarding agency and make sure the approved support is kept on file.
Federal Agency: Department of Justice
Federal Program Name: Services for Victims of Human Trafficking
Assistance Listing Number: 16.320
Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003,
15POVC-21-GG-03694-HT (2021), and 2020-HT-OVC-614
Award Period: October 1, 2020 through September 30, 2024
Type of Finding:
• Material Weakness in Internal Control over Compliance
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of cash management. The Organization should have internal controls designed to ensure compliance with those provisions.
Condition: During our testing, we noted the Organization did not have adequate internal controls designed to ensure requests for reimbursement were supported by costs incurred and paid within 30 days.
Questioned costs: None
Context: During our testing, it was noted that there was no formal layer of review over the draw down requests prepared by the accountant before it was submitted to the awarding agency. Amounts drawn did not consistently agree to known upcoming or previously incurred expenditures.
Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff.
Effect or potential effect: The auditor noted no instances of noncompliance with the provisions of cash management; however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance that could be material.
Repeat Finding: No
Recommendation: We recommend the Organization design controls to ensure the draw down requests and related support are formally reviewed and approved by the Executive Director before submitting the request to the awarding agency and that the support is retained.
Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the draw down request and support and before submission to the awarding agency and make sure the approved support is kept on file.
Federal Agency: Department of Justice
Federal Program Name: Services for Victims of Human Trafficking
Assistance Listing Number: 16.320
Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003,
15POVC-21-GG-03694-HT (2021), and 2020-HT-OVC-614
Award Period: October 1, 2020 through September 30, 2024
Type of Finding:
• Material Weakness in Internal Control over Compliance
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of cash management. The Organization should have internal controls designed to ensure compliance with those provisions.
Condition: During our testing, we noted the Organization did not have adequate internal controls designed to ensure requests for reimbursement were supported by costs incurred and paid within 30 days.
Questioned costs: None
Context: During our testing, it was noted that there was no formal layer of review over the draw down requests prepared by the accountant before it was submitted to the awarding agency. Amounts drawn did not consistently agree to known upcoming or previously incurred expenditures.
Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff.
Effect or potential effect: The auditor noted no instances of noncompliance with the provisions of cash management; however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance that could be material.
Repeat Finding: No
Recommendation: We recommend the Organization design controls to ensure the draw down requests and related support are formally reviewed and approved by the Executive Director before submitting the request to the awarding agency and that the support is retained.
Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the draw down request and support and before submission to the awarding agency and make sure the approved support is kept on file.
Federal Agency: Department of Justice
Federal Program Name: Services for Victims of Human Trafficking
Assistance Listing Number: 16.320
Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003,
15POVC-21-GG-03694-HT (2021), and 2020-HT-OVC-614
Award Period: October 1, 2020 through September 30, 2024
Type of Finding:
• Material Weakness in Internal Control over Compliance
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of allowable costs. The Organization should have internal controls designed to ensure compliance with those provisions.
Condition: Internal controls over compliance for allowable costs were not in place to support that the Organization was requesting reimbursement for costs allowable by the Federal Agency.
Questioned costs: None as the net impact of the two errors identified below are $0.
Context:
Indirect Allocations
In a sample of 8, 5 drawdown requests were submitted to the Federal Agency at a lower cost rate than the 10 percent de minimis threshold allowed for by the Federal Agency. 1 of the 8 was submitted at a higher rate than the 10 percent de minimis threshold. The net impact of the inconsistency of the rate being applied to each draw within our sample resulted in the Organization charging $2,115 less to the grant than earned.
Cash Disbursements (other than payroll related items)
In a sample of 7, 1 of the items included as an allowable cost was an error. The expense of $2,115 was incurred by the Organization but incorrectly posted in their accounting software. The support of the disbursement received supported that the cost was not allowable per the grant guidelines.
Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff.
Effect or potential effect: The amounts reimbursed by the Federal Agency may by unallowable and result in a refund to the Federal Agency.
Repeat Finding: No
Recommendation: We recommend the Organization design controls to ensure the draw down requests and related support are formally reviewed and approved by the Executive Director for allowability before submitting the request to the awarding agency.
Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the draw down request and support and before submission to the awarding agency and make sure the approved support is kept on file.
Federal Agency: Department of Justice
Federal Program Name: Services for Victims of Human Trafficking
Assistance Listing Number: 16.320
Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003,
15POVC-21-GG-03694-HT (2021), and 2020-HT-OVC-614
Award Period: October 1, 2020 through September 30, 2024
Type of Finding:
• Material Weakness in Internal Control over Compliance
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of allowable costs. The Organization should have internal controls designed to ensure compliance with those provisions.
Condition: Internal controls over compliance for allowable costs were not in place to support that the Organization was requesting reimbursement for costs allowable by the Federal Agency.
Questioned costs: None as the net impact of the two errors identified below are $0.
Context:
Indirect Allocations
In a sample of 8, 5 drawdown requests were submitted to the Federal Agency at a lower cost rate than the 10 percent de minimis threshold allowed for by the Federal Agency. 1 of the 8 was submitted at a higher rate than the 10 percent de minimis threshold. The net impact of the inconsistency of the rate being applied to each draw within our sample resulted in the Organization charging $2,115 less to the grant than earned.
Cash Disbursements (other than payroll related items)
In a sample of 7, 1 of the items included as an allowable cost was an error. The expense of $2,115 was incurred by the Organization but incorrectly posted in their accounting software. The support of the disbursement received supported that the cost was not allowable per the grant guidelines.
Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff.
Effect or potential effect: The amounts reimbursed by the Federal Agency may by unallowable and result in a refund to the Federal Agency.
Repeat Finding: No
Recommendation: We recommend the Organization design controls to ensure the draw down requests and related support are formally reviewed and approved by the Executive Director for allowability before submitting the request to the awarding agency.
Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the draw down request and support and before submission to the awarding agency and make sure the approved support is kept on file.
Federal Agency: Department of Justice
Federal Program Name: Services for Victims of Human Trafficking
Assistance Listing Number: 16.320
Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003,
15POVC-21-GG-03694-HT (2021), and 2020-HT-OVC-614
Award Period: October 1, 2020 through September 30, 2024
Type of Finding:
• Material Weakness in Internal Control over Compliance
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of allowable costs. The Organization should have internal controls designed to ensure compliance with those provisions.
Condition: Internal controls over compliance for allowable costs were not in place to support that the Organization was requesting reimbursement for costs allowable by the Federal Agency.
Questioned costs: None as the net impact of the two errors identified below are $0.
Context:
Indirect Allocations
In a sample of 8, 5 drawdown requests were submitted to the Federal Agency at a lower cost rate than the 10 percent de minimis threshold allowed for by the Federal Agency. 1 of the 8 was submitted at a higher rate than the 10 percent de minimis threshold. The net impact of the inconsistency of the rate being applied to each draw within our sample resulted in the Organization charging $2,115 less to the grant than earned.
Cash Disbursements (other than payroll related items)
In a sample of 7, 1 of the items included as an allowable cost was an error. The expense of $2,115 was incurred by the Organization but incorrectly posted in their accounting software. The support of the disbursement received supported that the cost was not allowable per the grant guidelines.
Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff.
Effect or potential effect: The amounts reimbursed by the Federal Agency may by unallowable and result in a refund to the Federal Agency.
Repeat Finding: No
Recommendation: We recommend the Organization design controls to ensure the draw down requests and related support are formally reviewed and approved by the Executive Director for allowability before submitting the request to the awarding agency.
Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the draw down request and support and before submission to the awarding agency and make sure the approved support is kept on file.
Federal Agency: Department of Justice
Federal Program Name: Services for Victims of Human Trafficking
Assistance Listing Number: 16.320
Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003,
15POVC-21-GG-03694-HT (2021), and 2020-HT-OVC-614
Award Period: October 1, 2020 through September 30, 2024
Type of Finding:
• Material Weakness in Internal Control over Compliance
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of allowable costs. The Organization should have internal controls designed to ensure compliance with those provisions.
Condition: Internal controls over compliance for allowable costs were not in place to support that the Organization was requesting reimbursement for costs allowable by the Federal Agency.
Questioned costs: None as the net impact of the two errors identified below are $0.
Context:
Indirect Allocations
In a sample of 8, 5 drawdown requests were submitted to the Federal Agency at a lower cost rate than the 10 percent de minimis threshold allowed for by the Federal Agency. 1 of the 8 was submitted at a higher rate than the 10 percent de minimis threshold. The net impact of the inconsistency of the rate being applied to each draw within our sample resulted in the Organization charging $2,115 less to the grant than earned.
Cash Disbursements (other than payroll related items)
In a sample of 7, 1 of the items included as an allowable cost was an error. The expense of $2,115 was incurred by the Organization but incorrectly posted in their accounting software. The support of the disbursement received supported that the cost was not allowable per the grant guidelines.
Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff.
Effect or potential effect: The amounts reimbursed by the Federal Agency may by unallowable and result in a refund to the Federal Agency.
Repeat Finding: No
Recommendation: We recommend the Organization design controls to ensure the draw down requests and related support are formally reviewed and approved by the Executive Director for allowability before submitting the request to the awarding agency.
Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the draw down request and support and before submission to the awarding agency and make sure the approved support is kept on file.