Finding 2024-002 Failure to Follow Procurement Policy Type of Finding Noncompliance and Significant Deficiency in Internal Control over Compliance Condition The Organization maintains a procurement policy that establishes spending thresholds and outlines the requirements for obtaining rate quotations at each of these levels. During audit procedures, it was noted that the Organization did not follow the policy’s requirements for obtaining and documenting rate quotations for two of the transactions reviewed. The Organization explained that the vendor was considered a unique partner, and competition was intentionally limited based on the specialized nature of the services provided. However, no documentation was retained to justify this decision to limit competition, as required by federal procurement standards. The absence of such documentation resulted in questioned costs for these transactions. Criteria: Federal regulations require non-federal entities to maintain written procurement procedures that are consistent with applicable laws and standards, including the requirement to conduct procurement transactions in a manner that provides full and open competition, except in limited circumstances, as specifically defined in 2 CFR 200.320. When competition is restricted, entities are required to document the basis for their determination, including the rationale for selecting a particular vendor. Additionally, entities must maintain documentation to support procurement actions and decisions to ensure compliance with applicable requirements. Cause This issue appears to stem from a lack of adherence to the Organization’s procurement policy and an underdeveloped process for documenting exceptions to competitive procurement requirements. While management considered the vendor relationship justified, there was no formal documentation of the rationale, resulting in noncompliance with both internal policy and federal procurement requirements. Possible of Known Effect As a result of this deficiency, the Organization cannot demonstrate that the procurement process complied with the federal requirements under 2 CFR 200.320, nor can it substantiate its rationale for limiting competition. This lack of documentation increases the risk of unsupported or inappropriate expenditures, and in this instance, led to questioned costs related to the two transactions tested. Questioned Costs Known questioned costs of $29,164 were identified. Repeat Finding This is not a repeat finding. Recommendation We recommend that the Organization strengthen its procurement practices by ensuring that all procurements, including those where competition is intentionally limited, are fully documented in accordance with federal requirements and the Organization’s procurement policy. Documentation should include the rationale for limiting competition and evidence of compliance with the applicable procurement threshold requirements. Implementing a review process to ensure procurement files are complete prior to payment or grant charging would further reduce the risk of noncompliance. Views of Responsible Officials Prior to the award of ARPA grant funding in 2023, the Organization did not have a formal procurement policy in place. Implementation of such a policy was required to receive the award. At the time of implementation, however, partnerships had already been established and were identified in the original grant proposal. With respect to legal services, the Organization engaged the two primary organizations in Indianapolis that provide expungement assistance. Indiana Legal Services ("ILS") was the first entity contacted, but after multiple attempts, no response was received from the designated point of contact. Subsequently, the Organization engaged with another nonprofit organization, which responded promptly and agreed to serve as a partner under the grant. For grant compliance services, the Organization engaged a third party. This decision was based on recommendations from community partners, as well as her demonstrated work quality, professional reliability, and commitment to serving the target population.
Finding 2024-001 Financial Close Process Type of Finding Material Weakness in Internal Control over Financial Reporting Condition During the audit, it was noted that the Organization lacked a robust financial close and review process. This deficiency resulted in material audit adjustments across key financial statement accounts, including revenue, accounts payable, accrued expenses, deferred revenue, nets assets, and related activity accounts. These adjustments were proposed by the auditors and subsequently recorded by management in order to fairly present the financial statements in accordance with generally accepted accounting principles. The extent and materiality of the adjustments indicate that the Organization's existing closing procedures were insufficient to identify and correct errors prior to the audit. Criteria Management is responsible for adopting sound accounting policies and establishing and maintaining a system of internal control for the fair presentation of the basis financial statements in accordance with accounting principles generally accepted in the United States of America. Cause The underlying cause appears to be a combination of a lack of formalized month-end and year-end close procedures. Without clearly defined timelines, responsibilities, and communication protocols, important financial information may not have been shared or reviewed in a timely manner, increasing the risk of errors or omissions during the close process. Possible of Known Effect Because of this gap in process and communication, material misstatements were present in the Organization’s financial records and required auditor-proposed adjustments to ensure the financial statements were fairly stated. While these corrections were made before issuance, the absence of a consistent and well-coordinated close process creates a risk that financial statements could be misstated in future periods if similar issues are not identified in advance. Recommendation We recommend that the Organization develop and implement a formal financial close process that includes clear timelines, assigned responsibilities, and review steps for all key account areas. In addition, improving communication protocols between program staff and accounting staff particularly around the timing and completeness of financial information will help ensure that the financial records are accurate and complete prior to the start of the audit. Views of Responsible Officials The Organization acknowledges this finding and agrees with the auditor’s assessment regarding the need for a more robust financial close and review process. We recognize that the absence of such a process contributed to the material audit adjustments noted during the engagement. Management and the Board are committed to strengthening internal controls and financial oversight to ensure that future financial statements are materially accurate and compliant with GAAP prior to audit. We are confident that the measures underway will address the deficiency and prevent recurrence.
Finding 2024-003 Insufficient Documentation Supporting Payroll Activity Type of Finding Significant Deficiency in Internal Control over Compliance Condition: During testing of payroll claims, we noted that the Organization did not consistently maintain documentation of approved pay rates. Some employees had offer letters on file, while others did not. In certain cases, the offer letters on file contained pay rates that did not match the actual pay rates being paid. Although our procedures and inquiries confirmed that employees were paid the correct amounts in accordance with approved procedures, the approved documentation was not consistently retained. In addition, we noted that the Organization did not maintain properly completed and approved I-9 forms for all employees during the year. Criteria: The Organization is required to maintain sufficient personnel documentation, including accurate records of approved pay rates and current I-9 forms, to demonstrate compliance with applicable employment laws and to support proper payroll processing. Federal law requires employers to retain completed Form I-9 for each employee to verify employment eligibility. Cause: The Organization’s personnel file maintenance procedures were not consistently followed. There was not an established process to ensure that all pay rate approvals and I-9 forms were documented, reviewed, and retained in employee personnel files. Possible of Known Effect: Failure to maintain accurate personnel records creates a risk that employees’ pay rates are not properly authorized and increases the risk of noncompliance with federal employment eligibility requirements. While compensating payroll controls reduced the risk of payroll errors, the lack of documentation represents a breakdown in internal control over human resources and payroll compliance. Questioned Costs: There were no questioned costs identified. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Organization implement and enforce procedures to ensure that personnel files contain complete and accurate documentation. Specifically, all employee files should include an approved record of pay rates (e.g., executed offer letters or updated personnel rate forms) and current I-9 forms. Management should designate responsibility for maintaining these records and periodically review personnel files to ensure compliance. Views of Responsible Officials: The organization recognizes the importance of maintaining complete and accurate payroll documentation and acknowledges the deficiencies identified during the audit. While payroll payments were made accurately, we recognize that inconsistent retention of supporting documentation created a compliance risk. Certain documentation had been maintained in digital form by a former staff member. Due to staff turnover, these records were not readily accessible or able to be located during the audit period. Management has since initiated a process to update all employee files with current, complete, and properly executed documentation to ensure compliance and improve recordkeeping practices. Management and leadership remain committed to strengthening personnel file management, maintaining all required documentation in accordance with applicable regulations, and reinforcing oversight to prevent recurrence in future audit periods.