Finding 2023-008—Ineffective Control Environment Material Weakness See Finding 2023-001 Federal Program: All federal awards. Questioned costs: None noted. Context: Management and those charged with governance failed to establish and consistently demonstrate a culture of integrity, accountability and compliance with internal control responsibilities. As a result, employees were not provided with clear and consistent expectations regarding adherence to policies, performance of control activities and resolution of identified control deficiencies. This weakened the overall control environment and undermined the effectiveness of controls throughout the organization. Repeat Finding: No Finding 2023-001—Ineffective Control Environment Material Weakness Criteria: Management is responsible for establishing and maintaining effective internal control over financial reporting. The COSO Internal Control – Integrated Framework identifies the Control Environment as the foundation of an effective system of internal control. Principle 1 requires management and those charged with governance to demonstrate a commitment to integrity and ethical values through their directives, actions and behaviors. An effective control environment promotes accountability, reinforces compliance with established policies and procedures, and establishes an organizational culture that supports reliable financial reporting. Condition: IFDC did not sufficiently establish and maintain an appropriate control environment that demonstrates a commitment to strong integrity, ethical values, accountability and adherence to established oversight mechanisms, and policies and procedures. During the audit we identified control issues and concerns related to adherence to established policies and procedures in one instance in which management failed to consistently reinforce responsibilities, respond appropriately to identified control deficiencies, and promote adherence to established policies and procedures during 2023, resulting in misappropriation of assets after year-end. In addition, we noted individuals responsible for financial reporting lacked sufficient knowledge and training to effectively perform assigned control activities. As a result, the foundation necessary to support effective internal control over financial reporting was not operating effectively. Cause: Management and those charged with governance did not sufficiently establish a culture to promote proper conduct, accountability, awareness, and compliance with internal control responsibilities throughout the organization. Oversight activities were not sufficient to ensure established policies and control expectations were consistently followed and enforced. Effect: An inefficient control environment can undermine the effectiveness of internal controls throughout the organization and increase the risk that errors, omissions or fraud, could occur and not be prevented, detected, or corrected on a timely basis. Because the control environment serves as the foundation for all other components of internal control, deficiencies in this area may affect the reliability of financial reporting across multiple account balances and transaction cycles. Recommendation: We recommend management and those charged with governance strengthen the control environment by: • Consistently demonstrating and communicating a commitment to integrity and ethical values. • Establishing clear expectations regarding compliance with internal controls and organizational policies. • Holding personnel accountable for adherence to internal control responsibilities. • Providing periodic ethics and compliance training. • Enhancing governance oversight of financial reporting and internal control matters. • Promptly addressing identified control deficiencies and instances of noncompliance. Views of responsible officials: Management acknowledges the findings and began reinforcing a stronger, more effective culture to promote ethical conduct as of end of 2023. See corrective action plan.
Finding 2023-009—Reconciliations of Accounts Material Weakness See Finding 2023-003 Federal Program: All federal awards. Questioned costs: None noted. Context: IFDC implemented or maintained an accounting system that was not properly configured to accurately carry forward prior-year audited balances into the current fiscal year. As a result, numerous balance sheet accounts contained beginning balances that did not reconcile to the audited 2022 financial statements and required significant management effort to investigate and reconcile. The inability of the accounting system to generate accurate beginning balances impaired management's ability to produce reliable financial information and increased the risk that errors or misstatements could occur and remain undetected. Because accurate financial records are necessary to prepare financial statements in accordance with 2 CFR 200.508 and other applicable reporting requirements, this condition represents a deficiency in the organization's financial reporting process. Repeat Finding: No Finding 2023-003—Reconciliations of Significant Accounts Material Weakness Criteria: In accordance with 2 CFR 200.508, the auditee must prepare appropriate financial statements. Management of IFDC has elected to follow generally accepted accounting principles (GAAP). Condition: During our audit, we noted various accounts that were not properly reconciled during the year; specifically, receivables and liabilities were overstated and grant revenue and subgrantee expenses were also overstated. IFDC was recording expense and liability and related grant revenue and receivable for amounts that were approved to be sent to the grantees but were instead in liabilities, overstating grant revenue and related subgrantee expenses and the Schedule of Expenditures of Federal Awards. Cause: The cause is a result of the lack of appropriate and timely reconciliations of the accounts and reviews during the fiscal year ended December 31, 2023. Effect: There were numerous entries during the audit, resulting in management having to reconcile all accounts and provide new trial balance and new schedules. Recommendation: We recommend that management revise internal control and review processes around monthly financial statements for financial reporting to ensure accurate preparation of the financial statements in accordance with GAAP. Subgrantee expenses and related grant revenue should be recognized when the expense is incurred. Views of responsible officials: Management agrees with the finding. See corrective action plan.
Finding 2023-010—Cash Management Material Weakness / Material Noncompliance Federal Program: All federal awards. Criteria: Under 2 CFR 200.305, entities must minimize the time between incurring costs and drawing federal funds or receiving reimbursement. Condition: Subgrantee amounts included amounts drawn down but not sent to the subgrantees in a timely manner. Management adjusted the amounts to reduce the subgrantee expenses and related revenue for the amounts that were not sent to subgrantees. Cause: Accounting was recording subgrantee expenses when the funds were drawn down and not when the funds were sent to the subgrantees. Effect: Overstatement of subgrantee expenses and the time between incurring costs and drawing federal funds was not minimized. Questioned costs: None noted. Context: IFDC recorded $1,016,519 in subgrantee expenses and related revenue for amounts that were drawn down but not sent to the subgrantees. Repeat Finding: No Recommendation: IFDC should minimize the time between incurring costs and drawing federal funds. Views of responsible officials and planned corrective actions: Management agrees with the finding. See corrective action plan.
Finding 2023-011—Suspension and Debarment Support Material Weakness / Material Noncompliance Federal Program: All federal awards. Criteria: Under 2 CFR 200.214 (Suspension and debarment) requires non-federal entities to comply with the requirements in 2 CFR Part 180 (and agency-specific supplements) and not enter into covered transactions with parties that are suspended, debarred, or otherwise excluded. Acceptable verification methods typically include: (1) checking SAM.gov for exclusion status, (2) obtaining a written certification from the entity, or (3) including appropriate clause/term in the subaward/contract and documenting verification before entering the covered transaction, consistent with 2 CFR Part 180 (Nonprocurement Debarment and Suspension). The OMB Compliance Supplement (Suspension & Debarment requirement) expects verification to occur prior to award (or at the time of contracting/subaward) and to be documented in the award file. Finding 2023-011—Suspension and Debarment Support (Continued) Condition: IFDC did not retain timely documentation evidencing that subrecipients/contractors under the federal program were checked for suspension and debarment status prior to award or payment. Management provided support that this was done but it was after the award and payment to vendors and subrecipients and no interim documentation of verification existed. Cause: Current IFDC policies do not require or explicitly define the timing (pre-award) and evidence (e.g., saved SAM record) for suspension/debarment verification for covered transactions. Effect: IFDC has increased risk that could enter or continue awards and transactions with excluded parties, resulting in noncompliance with 2 CFR 200.214 and 2 CFR Part 180. There is also potential financial risk if costs are disallowed or questioned due to awards and payments with ineligible parties. As of year-end, we did not identify any instance where a subrecipient/contractor was actually excluded; however, the lack of timely documentation represents noncompliance and a significant deficiency in internal control over compliance. Questioned costs: None noted. Context: IFDC recorded $5.1 million in subgrantee expenses and over $2.5 million in vendors that received over $25,000 during the year. Exceptions noted were not isolated and indicate a systematic documentation and control issue affecting the suspension and debarment requirement. Repeat Finding: No Recommendation: IFDC should update its policies and procedures to require pre-award verification for all covered transactions (as defined in 2 CFR Part 180) and to retain evidence (e.g., PDF/Screenshot of SAM.gov search results showing entity name, UEI, date/time stamp). In addition, IFDC should implement a standard pre-award checklist or system control (required field) to block award setup until a suspension/debarment verification date and evidence are recorded and establish monitoring procedures to confirm ongoing adherence and periodic re-checks when appropriate (e.g., multi-year awards at renewal or modification). Views of responsible officials and planned corrective actions: Management agrees with the finding. See corrective action plan.
Finding 2023-012—Subrecipient Monitoring Material Weakness Federal Program: All federal awards. Criteria: Under 2 CFR 200.302(b), the entity must maintain internal controls to ensure tracking, collection, and resolution of amounts owed by subrecipients (e.g., repayments, questioned costs, overpayments, or unallowable costs). In addition, under 2 CFR 200.331(d) and 200.332, pass-through entities must: • Monitor subrecipient activities to ensure federal funds are used for authorized purposes. • Ensure subrecipients take timely and appropriate action on deficiencies, including financial issues. • Review financial and performance reports. Finding 2023-012—Subrecipient Monitoring (Continued) • Verify that subrecipients have audits as required; follow up on any audit findings or amounts due to the pass-through entity. Condition: During our audit of IFDC’s subrecipient monitoring procedures, we identified that IFDC did not provide the support of the subgrantee annual reports and evidence of timely follow up. Cause: IFDC does not have formal written procedures requiring appropriate monitoring procedures to ensure that subrecipients are providing the necessary documentation for appropriate risk assessment and monitoring. Effect: Noncompliance with 2 CFR 200.331. In addition, there is weak oversight of federal funds passed through to subrecipients and potential material misstatement of subrecipient expenditures on the Schedule of Expenditures of Federal Awards (SEFA). Questioned costs: None noted. Context: IFDC passed through approximately $5 million to 25 subrecipients during the fiscal year and there was no evidence of timely receipt of the annual audits of each subrecipient. Management provided emails showing there was communication but there is no formal policy to require timely follow up and appropriate documentation. Repeat Finding: No Recommendation: IFDC should establish formal policies and procedures for subrecipient risk assessment and monitoring under 2 CFR 200.331. Views of responsible officials and planned corrective actions: Management agrees with the finding. See corrective action plan.
Finding 2023-013—Late Filing of the Data Collection Form Significant Deficiency / Other Matter Noncompliance Federal Program: All federal awards. Criteria: Under 2 CFR 200.512(a), the auditee must submit the Data Collection Form (DCF) and the reporting package to the Federal Audit Clearinghouse (FAC) within the earlier of: 1. 30 calendar days after receipt of the auditor’s reports, or 2. Nine months after the fiscal year-end. Condition: IFDC did not file its Data Collection Form and reporting package with the FAC within the required timeframe. Cause: IFDC did not have formal procedures assigning responsibility for completing and submitting the DCF and no review process to ensure timely submission. Effect: The data collection form was not filed timely. Finding 2023-013—Late Filing of the Data Collection Form (Continued) Questioned costs: None noted. Context: The data collection form for the year ended December 31, 2022, was not filed within nine months of year-end or within 30 calendar days after receipt of the auditor’s report as required by Uniform Guidance. Repeat Finding: No Recommendation: IFDC should develop and implement formal written procedures assigning responsibility for the submission of the DCF and reporting package. Views of responsible officials and planned corrective actions: Management agrees with the finding. See corrective action plan.