Audit 387413

Significant Deficiency in Internal Control over Compliance Compliance Requirement: Internal Controls (2 CFR §200.303) Criteria: Uniform Guidance (2 CFR §200.303) requires non-Federal entities to establish and maintain effective internal control over Federal awards, including policies and procedures that provide reasonable assurance of compliance with applicable Federal requirements. Condition: The Organization does not maintain formal, written policies and procedures addressing key Uniform Guidance compliance areas, including compensation and fringe benefits (2 CFR §200.430-§200.431). While certain procedures are performed in practice, controls are informal and not documented. Cause: Due to the Organization’s size and reliance on informal processes, management has not formalized compliance procedures into written policies. Effect: The absence of written policies increases the risk that Uniform Guidance requirements may be applied inconsistently, particularly in the event of staff turnover, and increases the likelihood that noncompliance may occur and not be detected timely. Questioned Costs: None. Statistical Sampling: Not applicable. Repeat Finding: No. Recommendation: We recommend the Organization update the accounting policy manual to include written policies surrounding compensation and fringe benefits in accordance with Uniform Guidance. Organization’s Response: The Organization’s response is included in their corrective plan.