Audit 383123

2024-001: Internal Controls Over SEFA Preparation Federal Assistance Listing Number: 21.027 Name of Program or Cluster: Coronavirus State and Local Fiscal Recovery Funds Agency: U.S. Department of the Treasury Criteria Per 2 CFR §200.510(b), non-federal entities that expend $750,000 or more in federal awards during the fiscal year are required to prepare a SEFA that includes accurate and complete information about all federal awards expended. The Uniform Guidance also emphasizes the importance of internal control systems over compliance and reporting, as outlined in 2 CFR §200.303. Entities must establish and maintain effective internal controls to ensure compliance with federal statutes, regulations, and the terms and conditions of federal awards Condition Life Management, Inc. (LMI) does not appear to have implemented sufficient internal controls to ensure the complete and accurate preparation of the Schedule of Expenditures of Federal Awards (SEFA) for the year ended December 31, 2024. Although LMI’s SEFA preparation memo states that the Chief Financial Officer (CFO) is responsible for compiling the SEFA using information from the accounting system and supporting grant documentation, in practice, we noted that the entity relied on an external entity to provide essential grant documentation necessary for SEFA preparation. Additionally, the SEFA/SESFA provided appeared to be outdated and not reflective of current-year grant activity. Cause The absence of a fully developed control structure and oversight mechanism appears to have contributed to reliance on external or related-party sources for preparing SEFA-related documentation. This suggests a lack of staff with adequate skills, knowledge, and experience (SKE) necessary for SEFA preparation. Repeat Finding No Recommendation We recommend that Life Management, Inc. strengthen its internal control processes over SEFA preparation. This may include: • Providing training to appropriate staff to ensure they have the requisite skills, knowledge, and experience to independently prepare the SEFA in accordance with federal requirements. • Engaging or hiring qualified personnel with federal grant accounting expertise to oversee the SEFA preparation process. • Reducing reliance on external or related parties for documentation by maintaining a centralized, internal repository of grant agreements and related records. Views of Responsible Officials See Corrective Action Plan