Finding 2024-004: Non-Compliance with Suspension and Debarment (Significant Deficiency)
Information on the Federal Program: 93.368
Criteria: 2 CFR §200.213 non-Federal entities are subject to the non-procurement debarment and
suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These
regulations restrict awards, subawards, and contracts with certain parties that are debarred,
suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs
or activities. The non-Federal entity must verify that the person with whom you intend to do business
is not excluded or disqualified, by (a) Checking SAM Exclusions; or (b) Collecting a certification from
that person; or (c) Adding a clause or condition to the covered transaction with that person.
Condition: We noted that while the Foundation does conduct screenings on all vendors, suppliers
and consultants, the date that the screening is conducted is not documented. As such, we are unable
to determine if the screening was conducted prior to payment or signing of the contract.
Cause: The Foundation does not require that the date the screening is conducted be documented.
Effect or Potential Effect: Failure to screen potential and current vendors, suppliers or contractors
prior to payment or contract signing increases the potential that Federal funds be inadvertently
provided to parties deemed to be suspended or disbarred by the United States Government.
Questioned Costs: None noted.
Context: Our audit procedures consisted of testwork completed on individual expenditures charged
to the Federal awards. The report in which samples were selected was generated directly from the
Foundation's general ledger (accounting system). We consider our sample to be representative of
the population. The condition appeared to be systematic in nature.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Foundation revise their policy regarding suspension and
debarment to require that all screenings are accompanied by the documented date in which they
were conducted.
Finding 2024-005: Reporting (Significant Deficiency)
Information on the Federal Program: 93.368
Criteria: As noted in 2 CFR §200.303 "The non-Federal entity must 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).
Condition: We noted that while the Foundation does not have a formal review and approval process
in place over performance and financial reports that is documented and available for examination.
Cause: The Foundation does not document their review and approval process over performance and
financial reports.
Effect or Potential Effect: Without the proper approval processes in place over performance and
financial reports, there exists the potential for reporting errors.
Questioned Costs: None noted.
Context: Our audit procedures consisted of testwork performed over a sample of reports required to
be submitted during the year under audit. We consider our sample to be representative of the
population. The issue appears to be systematic in nature.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Foundation ensure that all approvals over performance
and financial reporting are clearly documented and available for examination.
Finding 2024-006: Timekeeping and Payroll Allocations (Significant Deficiency)
Information on the Federal Program: 93.368
Criteria: According to 2 CFR Section 200.430(i) charges to Federal awards for salaries and wages
must be based on records that accurately reflect the work performed. These records must:
i. Be supported by a system of internal control which provides reasonable assurance that the
charges are accurate, allowable, and properly allocated;
ii. Be incorporated into the official records of the non-Federal entity;
iii. Reasonably reflect the total activity for which the employee is compensated by the non-Federal
entity, not exceeding 100% of compensated activities;
iv. Encompass federally-assisted and all other activities compensated by the non-Federal entity on
an integrated basis, but may include the use of subsidiary records as defined in the non-Federal
entity’s written policy;
v. Comply with the established accounting policies and practices of the non-Federal entity;
vii. Support the distribution of the employee’s salary or wages among specific activities or cost
objectives if the employee works on more than one Federal award; a Federal award and non-
Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities
which are allocated using different allocation bases; or an unallowable activity and a direct or
indirect cost activity.
viii. Budget estimates (i.e., estimates determined before the services are performed) alone do not
qualify as support for charges to Federal awards.”
Condition: We noted that while the Foundation does keep timesheets, we noted several instances in
which the timesheets lacked evidence of supervisory approval. In addition, we noted several
instances in which the timesheet was not dated when approved.
Cause: The Foundation does not document their review and approval process consistently over
timesheets.
Effect or Potential Effect: Without the proper, documented, approval processes in place over
timesheets, there exists the potential for allocation errors.
Questioned Costs: Undetermined, as the allocations are based on employee timesheets, but it is
undeterminable if those timesheets were truly accurate due to the lack of consistent, documented
approval over the timesheets by a supervisor.
Context: Our audit procedures consisted of testwork performed over a sample of timesheets
submitted during the year under audit. We consider our sample to be representative of the
population. The issue appears to be systematic in nature.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Foundation ensure that all approvals over timesheets
are clearly documented and dated.
Finding 2024-007 Federal Award Management and Internal Controls (Material Weakness)
Information on the Federal Program: 93.368
Criteria: As noted in 2 CFR §200.303 "The non-Federal entity must 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).
Condition: During our audit, we noted that management was unable to prepare the Schedule of
Expenditures of Federal Awards (SEFA) without assistance. In addition, we noted that formalized,
documented internal control policies have not been established over various areas of Federal award
management.
Cause: The Foundation's controls are not adequately designed, and staff within the Foundation are
not properly trained on Federal award management and reporting.
Effect or Potential Effect: Without the proper controls in place, there exists the potential for
reporting errors and the misappropriation of funds.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend the Foundation formalize internal control procedures over all
compliance areas that are adequately communicated to staff. In addition, the Foundation should
ensure all staff are properly trained on Federal award management and reporting.
Finding 2024-004: Non-Compliance with Suspension and Debarment (Significant Deficiency)
Information on the Federal Program: 93.368
Criteria: 2 CFR §200.213 non-Federal entities are subject to the non-procurement debarment and
suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These
regulations restrict awards, subawards, and contracts with certain parties that are debarred,
suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs
or activities. The non-Federal entity must verify that the person with whom you intend to do business
is not excluded or disqualified, by (a) Checking SAM Exclusions; or (b) Collecting a certification from
that person; or (c) Adding a clause or condition to the covered transaction with that person.
Condition: We noted that while the Foundation does conduct screenings on all vendors, suppliers
and consultants, the date that the screening is conducted is not documented. As such, we are unable
to determine if the screening was conducted prior to payment or signing of the contract.
Cause: The Foundation does not require that the date the screening is conducted be documented.
Effect or Potential Effect: Failure to screen potential and current vendors, suppliers or contractors
prior to payment or contract signing increases the potential that Federal funds be inadvertently
provided to parties deemed to be suspended or disbarred by the United States Government.
Questioned Costs: None noted.
Context: Our audit procedures consisted of testwork completed on individual expenditures charged
to the Federal awards. The report in which samples were selected was generated directly from the
Foundation's general ledger (accounting system). We consider our sample to be representative of
the population. The condition appeared to be systematic in nature.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Foundation revise their policy regarding suspension and
debarment to require that all screenings are accompanied by the documented date in which they
were conducted.
Finding 2024-005: Reporting (Significant Deficiency)
Information on the Federal Program: 93.368
Criteria: As noted in 2 CFR §200.303 "The non-Federal entity must 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).
Condition: We noted that while the Foundation does not have a formal review and approval process
in place over performance and financial reports that is documented and available for examination.
Cause: The Foundation does not document their review and approval process over performance and
financial reports.
Effect or Potential Effect: Without the proper approval processes in place over performance and
financial reports, there exists the potential for reporting errors.
Questioned Costs: None noted.
Context: Our audit procedures consisted of testwork performed over a sample of reports required to
be submitted during the year under audit. We consider our sample to be representative of the
population. The issue appears to be systematic in nature.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Foundation ensure that all approvals over performance
and financial reporting are clearly documented and available for examination.
Finding 2024-006: Timekeeping and Payroll Allocations (Significant Deficiency)
Information on the Federal Program: 93.368
Criteria: According to 2 CFR Section 200.430(i) charges to Federal awards for salaries and wages
must be based on records that accurately reflect the work performed. These records must:
i. Be supported by a system of internal control which provides reasonable assurance that the
charges are accurate, allowable, and properly allocated;
ii. Be incorporated into the official records of the non-Federal entity;
iii. Reasonably reflect the total activity for which the employee is compensated by the non-Federal
entity, not exceeding 100% of compensated activities;
iv. Encompass federally-assisted and all other activities compensated by the non-Federal entity on
an integrated basis, but may include the use of subsidiary records as defined in the non-Federal
entity’s written policy;
v. Comply with the established accounting policies and practices of the non-Federal entity;
vii. Support the distribution of the employee’s salary or wages among specific activities or cost
objectives if the employee works on more than one Federal award; a Federal award and non-
Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities
which are allocated using different allocation bases; or an unallowable activity and a direct or
indirect cost activity.
viii. Budget estimates (i.e., estimates determined before the services are performed) alone do not
qualify as support for charges to Federal awards.”
Condition: We noted that while the Foundation does keep timesheets, we noted several instances in
which the timesheets lacked evidence of supervisory approval. In addition, we noted several
instances in which the timesheet was not dated when approved.
Cause: The Foundation does not document their review and approval process consistently over
timesheets.
Effect or Potential Effect: Without the proper, documented, approval processes in place over
timesheets, there exists the potential for allocation errors.
Questioned Costs: Undetermined, as the allocations are based on employee timesheets, but it is
undeterminable if those timesheets were truly accurate due to the lack of consistent, documented
approval over the timesheets by a supervisor.
Context: Our audit procedures consisted of testwork performed over a sample of timesheets
submitted during the year under audit. We consider our sample to be representative of the
population. The issue appears to be systematic in nature.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Foundation ensure that all approvals over timesheets
are clearly documented and dated.
Finding 2024-007 Federal Award Management and Internal Controls (Material Weakness)
Information on the Federal Program: 93.368
Criteria: As noted in 2 CFR §200.303 "The non-Federal entity must 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).
Condition: During our audit, we noted that management was unable to prepare the Schedule of
Expenditures of Federal Awards (SEFA) without assistance. In addition, we noted that formalized,
documented internal control policies have not been established over various areas of Federal award
management.
Cause: The Foundation's controls are not adequately designed, and staff within the Foundation are
not properly trained on Federal award management and reporting.
Effect or Potential Effect: Without the proper controls in place, there exists the potential for
reporting errors and the misappropriation of funds.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend the Foundation formalize internal control procedures over all
compliance areas that are adequately communicated to staff. In addition, the Foundation should
ensure all staff are properly trained on Federal award management and reporting.