Audit 373783

Lack of Independent Review and Approval of Reporting Finding Type. Immaterial Noncompliance. Significant Deficiency in Internal Control over Compliance (Reporting). Program. COVID-19 - Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; Assistance Listing Number 21.027, All Award Numbers Criteria. Recipients of federal awards are required to report periodically on financial information, as specified by the 2 CFR 200 Compliance Supplement or grant agreement. Reported information should be supported by the entity’s accounting records and subjected to an independent review and approval prior to submission in order to detect and correct any errors or omissions. Condition. The Organization is required to submit quarterly reports on the grant expenditures, and we noted that these reports are not subjected to an independent review and approval process. Cause. This condition was caused by the lack of understanding by program staff of the specific requirements of reporting. Effect. The Organization was exposed to an increased risk that the reports filed could contain errors and not be detected and corrected on a timely basis. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted. Recommendation. We recommend that the Organization review its procedures for compiling financial data for external reporting purposes and develop an independent review process before report submission. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.

Failure to Implement Required Written Policies Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Control over Compliance (Cash Management and Allowable Costs/Cost Principles). Program. COVID-19 - Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; Assistance Listing Number 21.027, All Award Numbers Criteria. The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to various areas, including: 1) Payments (draws of federal funds and how to minimize the time elapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302 (6)); 2) Procurement (including bidding and a conflict of interest policy) (§200.318); 3) Allowability of costs charged to federal programs (§200.302 (7)); 4) Compensation (personnel and benefits policy) (§200.430 and §200.431); and 5) Travel costs (including mileage and per diem) (§200.474). Condition. There are no written policies in place covering payments, procurement, allowability of costs charged to federal programs, compensation, or travel costs. Cause. This condition appears to have been caused by a lack of knowledge of applicable federal compliance requirements. Effect. As a result of this condition, the Organization did not fully comply with the Uniform Guidance. Questioned Costs. No costs are required to be questioned as a result of this finding. Recommendation. We recommend that written policies be put in place for all required processes to comply with requirements. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.