Audit 368202

Finding 2023-005 Cost Share Information on the Federal Programs: Assistance Listing Number #19.415 Criteria or Specific Requirement: Under 2 CFR 200.306 the following criteria apply for cost share funds: (1) Are verifiable in the recipient's or subrecipient's records; (2) Are not included as contributions for any other Federal award; (3) Are necessary and reasonable for achieving the objectives of the Federal award; (4) Are allowable under subpart E; (5) Are not paid by the Federal Government under another Federal award, except where the program's Federal authorizing statute specifically provides that Federal funds made available for the program can be applied to cost sharing requirements of other Federal programs; (6) Are provided for in the approved budget when required by the Federal agency; and (7) Conform to other applicable provisions of this part. Condition: Certain awards under the assistance listing number included cost share requirements, but ICFJ was unable to provide a schedule to identify the cost share requirements met during the year. Cause: ICFJ experienced transition during the fiscal year and certain documents and schedules were unable to be located during the audit process. Effect or Potential Effect: Lack of records related to cost share increase the chance of noncompliance and potential questioned costs. Questioned Costs: None. Context: We noted two out of the four awards within the assistance listing number included a cost share requirement. Neither of these awards ended during the current year. Identification as a Repeat Finding, if Applicable: Not applicable. Recommendation: We recommend that management of ICFJ implement procedures and control processes to track cost share requirements and the progress towards the requirements. Support for the cost share claimed should also be available upon request.

Finding 2023-002 Federal Funding Accountability and Transparency Act Subaward Reporting Information on the Federal Program: Assistance Listing Number #98.001 Criteria: As noted in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements who make first tier subawards of $30,000 or more are required to register in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) and report subaward data through FSRS. Condition: ICFJ was unable to provide documentation that they registered their subawards in the Federal Funding Accountability and Transparency Act Subaward Reporting System. Cause: ICFJ experienced transition in the accounting department during the year. Certain reports were not able to be retrieved during the audit. Effect or Potential Effect: ICFJ could inadvertently fail to ensure that subrecipients are in compliance with Federal award agency regulations. Questioned Costs: None noted. Context: ICFJ did not register their subawards in excess of $30,000 with the Federal Funding Accountability and Transparency Act Subaward Reporting System. Identification as a Repeat Finding, if Applicable: Yes, prior year finding 2022-001. Recommendation: We recommend that ICFJ update its policies and procedures to ensure all first tier subawards in excess of $30,000 are accurately and timely registered with the Federal Funding Accountability and Transparency Act Subaward Reporting System. In addition, ICFJ should ensure any subawards are reported within the required time-frame.

Finding 2023-003 Reporting Information on the Federal Program: Assistance Listing Numbers #98.001, #19.415 Criteria: In accordance with 2 CFR Part 200.328 the recipient or subrecipient must submit financial reports as required by the Federal award. Condition: ICFJ was unable to locate certain reports submitted during the year. Cause: ICFJ experienced transition in the accounting department during the year. Certain reports were not able to be retrieved during the audit. Effect or Potential Effect: Although it is our understanding that ICFJ believes that all reports were submitted as required, it is not possible to verify compliance with the reporting requirements if the reports cannot be provided for the audit. Questioned Costs: None. Context: Our audit procedures consisted of testwork performed over reports submitted to the Federal Government. We consider our sample to be representative of the population. The condition appears to be systemic in nature. Identification as a Repeat Finding, if Applicable: Not applicable. Recommendation: We recommend that ICFJ ensure that all financial and programmatic reports are filed using a system that will permit them to be easily retrieved when needed for audit or other purposes.

Finding 2023-004 Cash Management Information on the Federal Programs: Assistance Listing Numbers #98.001, #19.415 Criteria or Specific Requirement: Under 2 CFR 200.303, organizations that receive Federal funding are required to “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: Evidence of review/approval for certain drawdown requests could not be provided. The supporting documentation for certain requests (i.e. the schedule documenting the calculation for the amount requested) was also not available. While management asserts that a review and approval of drawdown requests occurred, there is no audit trail that shows the evidence of the control occurring. Cause: ICFJ experienced transition during the fiscal year and certain documents were unable to be located during the audit process. Effect or Potential Effect: Appropriate procedures and documentation for drawdown requests is important to ensure compliance with cash management compliance requirements. Questioned Costs: None. Context: Our audit procedures consisted of testwork performed over cash receipts and drawdown requests from the Federal Government. We consider our sample to be representative of the population. The condition appears to be systemic in nature. Identification as a Repeat Finding, if Applicable: Not applicable. Recommendation: We recommend that management of ICFJ implement procedures and control processes to incorporate and document an independent review and approval, evidenced by a signature/initialing and date of the review and approval taking place prior to submission to the funder. Each request should be filed with the documentation supporting the calculation of the request.