Finding 2024-005 Subaward Monitoring Federal Agencies: U.S. Department of State Federal Programs: International Programs to Support Democracy, Human Rights, and Labor Assistance Listing Numbers: 19.345 Pass-through Entity: None Award Identification Number and Year: S-LMAQM-20-GR-2099, S-LMAQM-20-GR-2100, SAQMIP- 22-GR-0005, S-AQMIP-23-GR-0343 Criteria or Specific Requirement: As noted in 2 CFR Part 200.332 all pass-through entities must evaluate each subrecipient’s risk of noncompliance. Pass-through entity monitoring must include reviewing financial and performance reports required by the pass-through entity, and following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. Condition: ICFJ was unable to provide documentation that a pre-award risk assessment had occurred for a subrecipient sampled during the audit. Cause: ICFJ experienced transition during the fiscal year and certain documents were unable to be located during the audit process. Effect or Potential Effect: Subrecipient monitoring is important to ensure proper stewardship and use of Federal funding. Questioned Costs: None Context: The program only included one significant subrecipient. Identification as a Repeat Finding, if Applicable: Not applicable Recommendation: We recommend that ICFJ revisit their sub-recipient policies and ensure that all risk assessments are complete and approved prior to working with a subrecipient, all reporting includes indication of person submitting, date submitted, as well as person reviewing and approving and date. RCA audits, when applicable, should be obtained and reviewed annually. Documentation of this review (or documentation that the requirement does not apply) should be maintained as well.
Finding 2024-001 Audit Delays Federal Agencies: U.S. Department of State and U.S. Agency for International Development Federal Programs: International Programs to Support Democracy, Human Rights and Labor and Foreign Assistance for Programs Overseas Assistance Listing Numbers: 19.345 and 98.001 Pass-through Entity: None Award Identification Number and Year: S-LMAQM-20-GR-2099, S-LMAQM-20-GR-2100, SAQMIP- 22-GR-0005, S-AQMIP-23-GR-0343, 720-523-18-CA-00006, 720-486-23-LA-00001 Criteria or Specific Requirement: As noted in 2 CFR §200.303 "The non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)". As noted in 2 CFR §200.512 the audit report should be submitted nine months after the end of the audit period. Condition: There were delays in performing the audit, resulting in a late filing of the Uniform Guidance audit. In addition, we noted that certain accounts had not been reconciled throughout the year, but instead as part of audit preparation only. We noted that reconciliation of the indirect rate had also been delayed due to late receipt of a final rate and that further analysis is pending to determine any adjustments that may be required from the final rate determination. Cause: The above conditions arose due to numerous factors, including transition and turnover within the accounting department. Effect or Potential Effect: Timely year-end closure is important to avoid increased potential for fraud, misstatements, and failures to adhere to donor and other regulations. Effective filing of documents decreases the potential for non-compliance with donor requirements, questioned costs or findings. Questioned Costs: None Context: ICFJ has been impacted by funding changes as well as transition in staff within the acconting department. Identification as a Repeat Finding, if Applicable: Not applicable Recommendation: We recommend that ICFJ ensure that a monthly close process is followed to ensure timely and accurate financial reporting, transparent documentation of review and approval of transactions, and compliance with applicable donor requirements. Financial and compliance documents should be filed to permit prompt retrieval.
Finding 2024-002 Salary Allocations Federal Agencies: U.S. Agency for International Development Federal Programs: Foreign Assistance for Programs Overseas Assistance Listing Numbers: 98.001 Pass-through Entity: None Award Identification Number and Year: 720-523-18-CA-00006, 720-486-23-LA-00001 Criteria or Specific Requirement: Title 2 U.S. Code of Federal Regulations (CFR) Part 200, paragraph 430 “Compensation – personal services” requires that charges to Federal awards for Salaries and Wages must be based on records that accurately reflect the work performed, and that these records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Additionally, these records must comply with established accounting policies and practices of the non-Federal entity. Condition: We noted 3 instances where the allocation per the timesheet did not match the program and supporting service allocation within the general ledger. Cause: There were errors in the posting to the general ledger. Effect or Potential Effect: Allocation errors could result in inadvertently mischarging salaries and wages to its various programs. Questioned Costs: $614 Context: Our audit work in this area consisted of a random sample selection of payroll periods and employees. We consider our sample to be representative of the population, and thus, is a statistically valid sample. Identification as a Repeat Finding, if Applicable: Not applicable Recommendation: We recommend that ICFJ review its payroll process to ensure that the allocations ultimately entered within the general ledger agree to the time charged per timesheets.
Finding 2024-003 Reporting Federal Agencies: U.S. Department of State and U.S. Agency for International Development Federal Programs: International Programs to Support Democracy, Human Rights and Labor and Foreign Assistance for Programs Overseas Assistance Listing Numbers: 19.345 and 98.001 Pass-through Entity: None Award Identification Number and Year: S-LMAQM-20-GR-2099, S-LMAQM-20-GR-2100, SAQMIP- 22-GR-0005, S-AQMIP-23-GR-0343, 720-523-18-CA-00006, 720-486-23-LA-00001 Criteria: In accordance with 2 CFR Part 200.328 the recipient or subrecipient must submit financial reports as required by the Federal award. Condition: ICFJ was unable to locate certain reports submitted during the year. Cause: ICFJ experienced transition in the accounting department during the year. Certain reports were not able to be retrieved during the audit. Effect or Potential Effect: Although it is our understanding that ICFJ believes that all reports were submitted as required, it is not possible to verify compliance with the reporting requirements if the reports cannot be provided for the audit. Questioned Costs: None Context: Our audit procedures consisted of testwork performed over reports submitted to the Federal Government. We consider our sample to be representative of the population. The condition appears to be systemic in nature. Identification as a Repeat Finding, if Applicable: This is a repeat finding (2023-003) Recommendation: We recommend that ICFJ ensure that all financial and programmatic reports are filed using a system that will permit them to be easily retrieved when needed for audit or other purposes.
Finding 2024-004 Cash Management Federal Agencies: U.S. Department of State and U.S. Agency for International Development Federal Programs: International Programs to Support Democracy, Human Rights and Labor and Foreign Assistance for Programs Overseas Assistance Listing Numbers: 19.345 and 98.001 Pass-through Entity: None Award Identification Number and Year: S-LMAQM-20-GR-2099, S-LMAQM-20-GR-2100, SAQMIP- 22-GR-0005, S-AQMIP-23-GR-0343, 720-523-18-CA-00006, 720-486-23-LA-00001 Criteria or Specific Requirement: Under 2 CFR 200.303, organizations that receive Federal funding are required to “establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award." These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Evidence of review/approval for certain drawdown requests could not be provided. The supporting documentation for certain requests (i.e. the schedule documenting the calculation for the amount requested) was also not available. While management asserts that a review and approval of drawdown requests occurred, there is no audit trail that shows the evidence of the control occurring. Cause: ICFJ experienced transition during the fiscal year and certain documents were unable to be located during the audit process. Effect or Potential Effect: Appropriate procedures and documentation for drawdown requests is important to ensure compliance with cash management compliance requirements. Questioned Costs: None Context: Our audit procedures consisted of testwork performed over cash receipts and drawdown requests from the Federal Government. We consider our sample to be representative of the population. The condition appears to be systemic in nature. Identification as a Repeat Finding, if Applicable: This is a repeat finding (2023-004) Recommendation: We recommend that management of ICFJ implement procedures and control processes to incorporate and document an independent review and approval, evidenced by a signature/initialing and date of the review and approval taking place prior to submission to the funder. Each request should be filed with the documentation supporting the calculation of the request.