Audit 390235

Improper Preparation of the Schedule of Expenditures of Federal Awards Condition: The Agency did not properly prepare the Schedule of Expenditures of Federal Awards ("SEFA") as required by 2 CFR 200.510(b). The Agency did not initially prepare a SEFA as it was unaware that it had expended $750,000 in federal awards, thereby triggering the requirement for a Single Audit. The Chief Financial Officer was unaware of which grants qualified as Federal awards, especially those passed through the State or County. The Chief Financial Officer was also unaware of how to prepare a SEFA once the federal awards had been determined. Criteria: Under 2 CFR 200.510(b), an auditee that expends the federal award threshold in a fiscal year must prepare a SEFA for the period covered by its financial statements, including each federal program's assistance listing number, federal agency, pass-through entity, if applicable, and total federal expenditures by program. The SEFA is required supplementary information used as the basis for planning and conducting the Single Audit, including the determination of major programs. Cause: The condition resulted from insufficient knowledge and training of accounting staff and management regarding SEFA requirements and the Single Audit process. Management had not established detailed procedures, including reconciliation of the SEFA to the general ledger and grant records, or a formal review process to ensure that all required elements and programs were included and properly presented. Effect: Because the SEFA was not initially completed, there was a risk that one or more federal programs would not be selected and tested as part of the Single Audit, potentially resulting in noncompliance with Uniform Guidance audit requirements. Inaccurate reporting of federal expenditures can affect the determination of major programs, potentially lead to questioned costs, and may cause federal agencies to or pass-through entities to view the auditee as noncompliant with Single Audit reporting requirements. The ARPA grant under Assistance Listing Number 21.027 (Coronavirus State and Local Fiscal Recovery Funds) was identified as the major program for testing. However, we later discovered an additional county-funded grant under the same Assistance Listing number that had not previously been communicated. This omission resulted in an initial testing sample from an incomplete population requiring additional procedures to correct the impact on the Single Audit. Questioned Cost: None noted as a result of audit procedures performed. Recommendation: Management should develop and implement written procedures for preparing the SEFA that: • Identify all active federal awards and related pass-through awards from grant agreements and award notices. • Reconcile SEFA amounts to the general ledger and the grant reporting records. • Ensure that required elements (federal agency, Assistance Listing number, pass-through entity, and total expenditures) are accurately presented for each program. • Provide for a secondary review by someone knowledgeable about federal grant requirements and Single Audit rules prior to finalizing the SEFA. Management Response: We agree with the findings in the audit report and have developed a Corrective Action Plan to address each item promptly. This has been a challenging year for the organization, including turnover in the Chief Financial Officer ("CFO") position and the fact that this was our first Single Audit due to increased federal funding related to COVID-19 programs. These factors contributed to delays in audit readiness, gaps in technical accounting for grants, and weaknesses in internal controls over financial reporting and federal award reporting. We have implemented a comprehensive plan to address these challenges and will be hiring a new CFO in the first quarter of 2026.

Lack of Written Procedures for Determining Allowability of Costs Condition: The Agency did not maintain written procedures for determining the allowability of costs charged to federal awards. Although management performs reviews of expenses to ensure reasonableness, these reviews are not guided by documented policies or standardized criteria. Criteria: In accordance with 2 CFR 200.302(b)(7), non-federal entities must maintain written procedures for determining allowability of costs in accordance with Subpart E - Cost Principles of the Uniform Administrative Requirements, Costs Principles, and Audit Requirements for Federal Awards ("Uniform Guidance"). Cause: Management was unaware that Uniform Guidance requires written procedures specifically addressing cost allowability, separate from general internal control or purchasing policies. Effect: Without documented procedures, there is an increased risk that unallowable or unsupported costs may be charged to federal programs, potentially resulting in noncompliance with federal cost principles and repayment obligations. Questioned Cost: None noted as a result of audit procedures performed. Recommendation: Management should develop and implement written procedures for determining allowability of costs consistent with the requirements of 2 CFR 200.302(b)(7). Procedures should clearly define responsibilities, documentation requirements, and approval processes to ensure all cost charged to federal programs are allowable, allocable, and reasonable. Management Response: We agree with the findings in the audit report and have developed a Corrective Action Plan to address each item promptly. This has been a challenging year for the organization, including turnover in the Chief Financial Officer ("CFO") position and the fact that this was our first Single Audit due to increased federal funding related to COVID-19 programs. These factors contributed to delays in audit readiness, gaps in technical accounting for grants, and weaknesses in internal controls over financial reporting and federal award reporting. We have implemented a comprehensive plan to address these challenges and will be hiring a new CFO in the first quarter of 2026.

Coronavirus State and Local Recovery Funds - Assistance Listing Number 21.027; Pass-through from State of Geogia Office of the Governor and Dekalb County; Grant Period: Year Ended December 31, 2024 Condition: The auditor's testing of payroll allocations for employees charging time to Coronavirus State and Local Recovery Funds, passed through from the State of Georgia Office of the Governor, identified instances where the hours allocated to the grant award did not precisely match the hours recorded on the employees' approved contemporaneous timesheets. In a sample of 48 transactions, 41 instances showed minor discrepancies. The discepancies included both overallocations (more hours charged to the program than recorded on the timesheets) and underallocations (fewer hours charged than recorded). While the total variance for the sample was determined to be immaterial, the result indicated a systemic control weakness. Criteria: Under 2 CFR 200.430(g)(1), charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and support the distribution of the employee's salary or wages among specific activities or costs objectives if the employee works on more than one federal award or a federal award and non-federal award. Cause: Management did not have sufficient internal controls or review procedures in place to ensure that the hours used for payroll allocation reconciled exactly to the source documentation (timesheets) on a consistent basis. The process relies on manual data entry, which was prone to minor errors, and did not include a robust, documented verification step. Effect: The Agency could potentially over or under allocate salaries and benefits to the program. Questioned Cost: None noted as a result of audit procedures performed. Recommendation: The Agency should implement a formal, documented monthly reconciliation process between the hours recorded on employee timesheets and the hours/percentages used for actual salary allocation to all federal awards. The entity should consider implementing an automated effort certification or time-tracking system to reduce manual errors and ensure consistency. Management Response: We agree with the findings in the audit report and have developed a Corrective Action Plan to address each item promptly. This has been a challenging year for the organization, including turnover in the Chief Financial Officer ("CFO") position and the fact that this was our first Single Audit due to increased federal funding related to COVID-19 programs. These factors contributed to delays in audit readiness, gaps in technical accounting for grants, and weaknesses in internal controls over financial reporting and federal award reporting. We have implemented a comprehensive plan to address these challenges and will be hiring a new CFO in the first quarter of 2026.