Audit 363273

FY End
2023-12-31
Total Expended
$1.05M
Findings
2
Programs
3
Organization: Frist Art Museum (TN)
Year: 2023 Accepted: 2025-07-29
Auditor: Kraftcpas PLLC

Organization Exclusion Status:

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Findings

ID Ref Severity Repeat Requirement
572166 2023-001 Significant Deficiency Yes I
1148608 2023-001 Significant Deficiency Yes I

Programs

Contacts

Name Title Type
NEQLSVRANRM8 Carol Vollbrecht Auditee
6157443356 Kenneth Youngstead Auditor
No contacts on file

Notes to SEFA

Title: BASIS OF PRESENTATION Accounting Policies: 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. FAM has elected not to use the 10-percent de minims indirect cost rate as allowed under the Uniform Guidance, however, no indirect costs have been charged to FAM’s grants. De Minimis Rate Used: N Rate Explanation: FAM has elected not to use the 10-percent de minims indirect cost rate as allowed under the Uniform Guidance, however, no indirect costs have been charged to FAM’s grants. The accompanying Schedule of Expenditures of Federal and State Awards (the “Schedule”) includes the federal and state grant activity of FAM and is presented on the accrual basis of accounting. The information in the Schedule of Expenditures of Federal and State Awards 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”) and the Audit Manual issued by the Comptroller of the Treasury of the State of Tennessee. Because the Schedule presents only a selected portion of the operations of FAM, it is not intended to and does not present the financial position, changes in net assets, or cash flows of FAM.
Title: SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES Accounting Policies: 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. FAM has elected not to use the 10-percent de minims indirect cost rate as allowed under the Uniform Guidance, however, no indirect costs have been charged to FAM’s grants. De Minimis Rate Used: N Rate Explanation: FAM has elected not to use the 10-percent de minims indirect cost rate as allowed under the Uniform Guidance, however, no indirect costs have been charged to FAM’s grants. 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. FAM has elected not to use the 10-percent de minims indirect cost rate as allowed under the Uniform Guidance, however, no indirect costs have been charged to FAM’s grants.
Title: SUBRECIPIENTS Accounting Policies: 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. FAM has elected not to use the 10-percent de minims indirect cost rate as allowed under the Uniform Guidance, however, no indirect costs have been charged to FAM’s grants. De Minimis Rate Used: N Rate Explanation: FAM has elected not to use the 10-percent de minims indirect cost rate as allowed under the Uniform Guidance, however, no indirect costs have been charged to FAM’s grants. FAM did not pass any federal awards through to subrecipients.

Finding Details

Federal Program Information Funding Agency: U.S. Department of Treasury Federal ALN: 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds Pass Through Agency: Tennessee Arts Commission Criteria As required by the Uniform Guidance, procurement standards require non-federal entities to follow documented procurement procedures that are in compliance with the procurement standards in the federal guidelines. Condition During the period under audit, FAM had a procurement policy in place, but it did not comply with the procurement standards in the federal guidelines. Cause FAM did not develop a procurement policy that included compliance with the micropurchase threshold requirements and therefore did not have a procurement policy in place that met the requirements of the Uniform Guidance. Effect Purchases may occur that do not meet the procurement standards. Context For the year ending December 31, 2023, all of the expenditures charged to the grant were over the $10,000 micropurchase threshold. While certain agreements in effect during the year could be subject to the procurement requirements, most were in effect prior to the start of the grant period or are for services such as utilities or professional services not subject to the procurement requirements. No new agreements were entered into during the year ending December 31, 2023, that were charged against the grant. Identification of a Repeat Finding This is a repeat finding from the immediate previous audit, 2022-002, which has been partially corrected. Auditor’s Recommendation FAM should ensure that the procurement policy subsequently implemented meets the procurement standards outlined in the Uniform Guidance, and should be followed for all purchases meeting the established thresholds. Views of Responsible Officials and Planned Corrective Actions Management agrees with the auditor’s recommendation. In FY 2022, FAM encountered difficulties complying with this criterion because the grant was not awarded and under contract until over nine months after the grant period began. Long-standing vendor relationships were already in place and so costs were incurred prior to award knowledge. In FY 2023, FAM had already incurred costs before the FY 2022 Uniform Guidance audit brought to our attention that our procurement policy did not comply with federal guidelines. FAM has developed a procurement policy that meets the procurement standards outlined in the Uniform Guidance including established thresholds.
Federal Program Information Funding Agency: U.S. Department of Treasury Federal ALN: 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds Pass Through Agency: Tennessee Arts Commission Criteria As required by the Uniform Guidance, procurement standards require non-federal entities to follow documented procurement procedures that are in compliance with the procurement standards in the federal guidelines. Condition During the period under audit, FAM had a procurement policy in place, but it did not comply with the procurement standards in the federal guidelines. Cause FAM did not develop a procurement policy that included compliance with the micropurchase threshold requirements and therefore did not have a procurement policy in place that met the requirements of the Uniform Guidance. Effect Purchases may occur that do not meet the procurement standards. Context For the year ending December 31, 2023, all of the expenditures charged to the grant were over the $10,000 micropurchase threshold. While certain agreements in effect during the year could be subject to the procurement requirements, most were in effect prior to the start of the grant period or are for services such as utilities or professional services not subject to the procurement requirements. No new agreements were entered into during the year ending December 31, 2023, that were charged against the grant. Identification of a Repeat Finding This is a repeat finding from the immediate previous audit, 2022-002, which has been partially corrected. Auditor’s Recommendation FAM should ensure that the procurement policy subsequently implemented meets the procurement standards outlined in the Uniform Guidance, and should be followed for all purchases meeting the established thresholds. Views of Responsible Officials and Planned Corrective Actions Management agrees with the auditor’s recommendation. In FY 2022, FAM encountered difficulties complying with this criterion because the grant was not awarded and under contract until over nine months after the grant period began. Long-standing vendor relationships were already in place and so costs were incurred prior to award knowledge. In FY 2023, FAM had already incurred costs before the FY 2022 Uniform Guidance audit brought to our attention that our procurement policy did not comply with federal guidelines. FAM has developed a procurement policy that meets the procurement standards outlined in the Uniform Guidance including established thresholds.