Audit 369728

Criteria: 2 CFR 200.303 includes requirements related to internal controls for federal award programs, including that the Organization must, among other things, “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 and Context: During 2024, the Organization reconciled the applicable match at the end of the grant period and submitted to the City of Indianapolis. There was no documentation on review of the schedule of the match nor was there a periodic assessment of the match until the reporting date. This is a repeat finding of 2023-003. Cause and Effect: We noted a lack of internal controls surrounding the tracking and review of the match. Errors could have occurred in the annual grant matching report which could have resulted in material non-compliance. Recommendation: We recommend the Organization implement procedures to track the match on a monthly basis with adequate review and approval. Views of Responsible Officials and Planned Corrective Actions: The Organization agrees with the recommendation and has implemented the recommendation noted.

Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-Federal entities receiving Federal funds to have certain written policies, procedures, and standards of conduct (policies) in place. Condition and Context: The Organization did not have the written policies in place in accordance with §200.302 Financial Management paragraph (b)(7), which requires written procedures for determining the allowability of costs in accordance with Subpart E of the Uniform Guidance and the terms and conditions of the federal award or §200.431 Compensation – Fringe Benefits paragraphs (b)(1) and (c), which requires written policies related to the payment of certain fringe benefits throughout all of 2024. This is a repeat finding of 2023-004. Cause and Effect: As the policies referenced above are not written, the Organization is not in compliance with the requirements. In addition, lack of written policies related to federal awards may lead to noncompliance with other federal requirements and the terms and conditions of federal awards. Recommendation: We recommend the policies in accordance with §200.302 Financial Management paragraph (b)(7) and §200.431 Compensation – Fringe Benefits paragraphs (b)(1) and (c) be written by the Organization, approved by the Board of Directors, and included in the permanent files of the Organization. Views of Responsible Officials and Planned Corrective Action: The Organization agrees with the recommendation and had implemented the required written policies as of December 31, 2024.