Audit 392932

Late Submission of Required Financial and Progress Reports Information on Federal Programs: Assistance Listing Number: 93.591 Family Violence Prevention and Services/State Domestic Violence Coalitions Criteria: Per Uniform Guidance 2 CFR 200 Subpart D, Performance and Financial Monitoring and Reporting, reports should be submitted within the required timeframe per the grant agreement and should tie out to the financial records. Documentation should also be kept for all financial and programmatic reports submitted for all federal awards. Condition: The Organization did not submit reports timely for three out of three reports tested (100%). We consider this condition to be a material weakness to the Reporting compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2022-003. Statistical sampling was not used in making sample selections. Questioned costs: None Effect: As a result of the late submission, the Organization is not in compliance with the reporting requirements of the Uniform Guidance. Cause: This resulted from human error and personnel changes at the accounting and management level. Recommendation: We recommend reviewing the controls in place to ensure that all future reports are submitted on time and in accordance with grant requirements. If the Organization expects that there will be a delay in the submission of the reports, they should obtain permission to extend the submission date from the awarding agency. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and their response is included with the Corrective Action Plan.

Expense Recorded in Incorrect Period of Performance Information on Federal Programs: Assistance Listing Numbers: 93.591 Family Violence Prevention and Services/State Domestic Violence Coalitions. Criteria: 2 CFR 200.309 notes “a non-Federal entity may charge to the Federal award only allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or passthrough entity made the Federal award that were authorized by the Federal awarding agency or pass-through entity.” Condition: Testing identified one expenditure out of a sample of seven (14.3%) were not properly recorded in the correct fiscal year. We consider this to be an instance of noncompliance in internal controls over compliance with Period of Performance and is not considered a repeated finding. Questioned Costs: $3,300 Effect: As a result, the Organization did not record an expenditure in the appropriate fiscal year. Cause: This is due to lack of controls over expenditure monitoring and miscommunications with employee turnover. Recommendation: Auditors recommend the organization implement procedures to review dates when expenditures are incurred and ensure they are accurately recorded and charged to the appropriate fiscal year for the grant period. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and their response is included with the Corrective Action Plan.

Unallowable Costs Information on Federal Programs: Assistance Listing Number: 93.671 Family Violence Prevention and Services/Domestic Violence Shelter and Supportive Services Criteria: 2 CFR 200.400 notes “a non-Federal entity must be consistent with these cost principles and support the accumulation of costs as required by the principles, and must provide for adequate documentation to support costs charged to the Federal award.” 2 CFR 200.309 notes “a non- Federal entity may charge to the Federal award only allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or passthrough entity made the Federal award that were authorized by the Federal awarding agency or passthrough entity.” 2 CFR 200.333 notes “financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the financial expenditure report." Condition: During our expenditure testing, we noted one out of thirty-seven expenditures that was an unallowable cost under the grant (2.7%). We consider this to be an instance of noncompliance in internal control over compliance relating to Allowable Costs/Cost Principles requirements and is not considered a repeated finding. Statistical sampling was not used in making sample selections. Questioned costs: $13,247 Effect: This resulted in a cost being allocated to a federal award that was unallowable. Cause: This resulted from human error and personnel changes at the accounting and management level. Recommendation: We recommend reviewing the controls in place to ensure that all costs are allowable to the grant charged. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and their response is included with the Corrective Action Plan.

Improper monitoring of subrecipients Information on Federal Programs: Assistance Listing Number: 93.671 Family Violence Prevention and Services/Domestic Violence Shelter and Supportive Services Criteria: 2 CFR 200.232 states “A pass-through entity must: (e) Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complied with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports. (2) Ensure that the subrecipient takes corrective action on all significant developments that negatively affect the subaward. Significant developments include Single Audit findings related to the subaward, other audit findings, site visits, and written notifications from a subrecipient of adverse conditions which will impact their ability to meet the milestones or the objectives of a subaward. When significant development negatively impact the subaward, a subrecipient must provide the pass-through entity with information on their plan for corrective action and any assistance needed to resolve the situation. (3) Issue a management decision for audit findings pertaining only to the Federal ward provided to the subrecipient from the pass- through entity as required by 200.521.(4) Resolve audit findings specifically related to the subaward. However, the pass-through entity is not responsible for resolving cross-cutting audit findings that apply the subaward and other Federal awards or subawards. If a subrecipient has a current Single Audit report and has not been excluded from receiving Federal funding (meaning, has not been debarred or suspended), the pass-through entity may rely on the subrecipient’s cognizant agency for audit or oversight agency for audit to perform audit follow-up and make management decisions related to cross-cutting audit findings in accordance with section 200.513(a)(4)(viii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that confirm to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. (f) Depending up on the pass-through entity’s assessment of the risk posed by the subrecipient, the following monitoring tools may be useful for the pass- through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; (2) Performing site visits to review the subrecipient’s program operations; and (3) Arranging for agreed-upon procedures engagements as described in 200.425.” Condition: Auditors noted there was missing documentary evidence of the following subrecipient monitoring requirements: obtain budgets for reasonable expenses from subrecipients, monitoring of quarterly subrecipient reports, subrecipient contract agreements, site visits, and receiving updated audit reports from subrecipients and issuing management decisions over federal award findings for pass through entities. We consider this condition to be a material weakness to the Subrecipient Monitoring compliance requirement and is not a repeated finding. Statistical sampling was not used in making sample selections. Questioned Costs: None Effect: As a result, the Organization was missing documentation relating to subrecipient monitoring requirements for the year ended September 30, 2023. Cause: This is due to ineffective controls over subrecipient monitoring resulting in a lack of documentation, and miscommunications with employee turnover. Recommendation: Auditors recommend that documentation be maintained for subrecipient monitoring and to implement site visits. In addition, the Organization should follow up and obtain audited financial statements each year from subrecipients and issue management decisions for federal award findings for pass through entities. Auditors also recommend implementing written policies and procedures over subrecipient monitoring. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and their response is included with the Corrective Action Plan.

Missing Written Cost Allocation Plan and Lack of Documentation Around Allocation Methodology and Lookback on Budget to Actual Analysis Information on Federal Programs: Assistance Listing Numbers: 93.591 Family Violence Prevention and Services/State Domestic Violence Coalitions. 93.671 Family Violence Prevention and Services/Domestic Violence Shelter and Supportive Services. Criteria: In accordance with the requirements in 2 CFR part 230 establishes cost principles for determining costs of grants, contracts, and other agreements with non-profit organizations. The principles are designed to provide that the Federal Government bear its fair share of costs except where restricted or prohibited by law. Administrative expenses are described as: “The expenses under this category are those that have been incurred for the overall general executive, and administration of the organization and other expenses of a general nature that do not relate solely to any major function of the organization." Condition: The Organization does not have a cost allocation plan in place. Due to this, there is a lack of documentation around allocation methodology and lookback on budget to actual analysis. We consider this to be a material weakness in internal controls over compliance with Allowable Costs/Cost Principles and is not considered a repeated finding. Questioned Costs: None Effect: As a result, the Organization does not have a written cost allocation plan to follow and administrative costs may not be sufficiently identified. As the Organization has more than one funding source, costs may be inequitably charged to programs. Cause:Although the Organization appears to be allocating costs, they still need to have written cost allocation plan created to make sure the plan is being followed and costs are charged appropriately to programs. Recommendation: Auditors recommend that the Organization review their system in place for cost allocation and implement a written cost allocation plan to ensure costs are charged appropriately to programs. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and their response is included with the Corrective Action Plan.