Information on the Federal Program: Assistance Listing Number 16.575?Crime Victim Assistance, United States Department of Justice. Pass-Through Entity: Colorado Department of Public Safety. Award Number: 2020-VA-21-562-02. Compliance Requirements: Allowable Costs Type of Finding Noncompliance and significant deficiency. Criteria: The Modified Total Direct Cost (MTDC) base, which is used to calculate the de minimis indirect cost rate, requires that payments over the grant period to contractors in excess of $25,000, be backed out of the MTDC base. Condition: In the third quarter of 2022, we identified an error in the MTDC, where payments to contractors in excess of $25,000 were not backed out properly. Context: One of the four quarters calculation of the indirect cost rate was found to have an error. Cause: There are a limited number of personnel to ensure adequate review is performed, prior to submitting quarterly reimbursements under the grant. Effect or Potential Effect: The Organization may be out of compliance with the terms and conditions of the grant. Questioned Costs: $1,020 Recommendation: The Organization should have controls in place to ensure a more robust review of quarterly reimbursements are performed, including the accuracy of the MTDC base used to calculate indirect costs. Views of Responsible Official: The Organization has hired a full-time Finance Director who will monitor these matters more closely than under the previous structure. The Organization will also review the current controls to ensure a more robust review of quarterly reimbursements are performed The organization will review policies and implement an action plan based on the availability of limited staff.
Information on the Federal Program: Assistance Listing Number 16.575?Crime Victim Assistance, United States Department of Justice. Pass-Through Entity: Colorado Department of Public Safety. Award Number: 2020-VA-21-562-02. Compliance Requirements: Allowable Costs Type of Finding Noncompliance and significant deficiency. Criteria: In accordance with the terms and conditions of the grant agreement, employee wages may be reimbursed for allowable costs up to a stated percentage. The quarterly draws submitted to the Colorado Department of Public Safety should be equal to, or document, any variances from the stated salary percentages allowed. Condition: We identified inconsistencies between the allocation of wages submitted for reimbursement to the Colorado Department of Public Safety, and what was allowed per the budget under the terms and conditions of the grant. Context: Out of our sample of 10 quarterly wages submitted for reimbursement, 3 employees were reimbursed at a higher percentage than was allowable under the terms and conditions of the grant. Time records were available to support the amount charged to the grant, but were not in accordance with the terms and conditions of the grant. The differences were not identified or supported in the submission for reimbursement. Controls did not appear to be operating effectively to prevent or detect the discrepancy between the approved grant budget and the wages charged to reimbursement. Cause: There are a limited number of personnel to ensure adequate review is performed, prior to submitting quarterly reimbursements under the grant. Effect or Potential Effect: The Organization may be out of compliance with the terms and conditions of the grant. Questioned Costs: None. Recommendation: The Organization should have controls in place to ensure a more robust review of quarterly reimbursements are performed, and document any variances from the allowed wages in the grant agreement, and what is being submitted for reimbursement. Views of Responsible Official: The Organization has hired a full-time Finance Director who will monitor these matters more closely than under the previous structure. The Organization will also review the current controls to ensure a more robust review of quarterly reimbursements are performed and will document any variances from the allowed wages in the grant agreement, and what is being submitted for reimbursement. The organization will review policies and implement an action plan based on the availability of limited staff.
Information on the Federal Program: Assistance Listing Number 16.575?Crime Victim Assistance, United States Department of Justice. Pass-Through Entity: Colorado Department of Public Safety. Award Number: 2020-VA-21-562-02. Compliance Requirements: Allowable Costs Type of Finding Noncompliance and significant deficiency. Criteria: As outlined in the Department of Justice Financial Guide, all grant recipients are required to complete and keep on file the U.S. Citizenship and Immigration Services? Employment Eligibility Verification Form I-9 for individuals working under the award. Condition: We were unable to obtained a completed I-9 for one employee working under the award. Context: Out of our sample of 9 employees, we were unable to obtain and I-9 for 1 employee. Cause: Employee was hired during the Covid-19 pandemic, the I-9 was overlooked as the hiring process was completed virtually. Effect or Potential Effect: Failure to obtain I-9?s as required may result in ineligible employees being permitted to work on the aware. This is considered material non-compliance with the grant agreement.Questioned Costs: None. Recommendation: The Organization should have a new hire checklist, that includes a I-9 is completed for each employee that is working under Department of Justice grant funding. Additionally, the Organization should review controls to ensure I-9?s for all employees are obtained and maintained. Views of Responsible Official: Once Project Safeguard realized that the organization didn?t have a copy of the file from the Board of Directors from the Executive Director having been hired in 2013, Project Safeguard has rectified the situation by replacing the missing I-9 with an updated I-9 with attestation in accordance to guidance from UCIS . All I-9s are completed and maintained in a separate file as soon as employment begins and E-verify is completed within three days of employment as stated in the Project Safeguard policies.
Criteria: The preparation of the financial statements and the related notes are the responsibility of management. Condition: Auditor is required to report on whether the Organization is able to prepare financial statements in accordance with GAAP. The preparation of financial statements in accordance with GAAP requires internal controls over both 1) recording, processing, and summarizing accounting data, and 2) the presentation of the organization?s financial statements, disclosures, supplementary information, schedule of federal and state financial assistance in conformity with generally accepted accounting principles (GAAP) of the United States. Internal control system does not include a process for preparing the annual financial statements and related disclosures in accordance with GAAP. The Organization?s ability to prepare financial statements in accordance with GAAP is based, in part, on its reliance on its external auditors, who cannot by definition be considered part of the Organization?s internal controls. Material adjustments were required to present the statements in accordance with GAAP. Cause: There are a limited number of office employees and resources available to allow for adequate preparation of the financial statements. Effect or Potential Effect: Potential for undetected errors, or material misstatements. Specifically adjustments related to investments, in-kind contributions and the recording of right to use assets in accordance with 842, were posted in order to present the statements in accordance with GAAP. Completeness of the financial statement disclosures and accuracy of the overall financial presentation are negatively impacted as outside auditors do not have the same comprehensive understanding of the Organization as its internal financial staff.Questioned Costs: None. Recommendation: The Organization should implement controls to ensure material adjustments are posted prior to the audit. Additionally, the Organization should continue to review the cost/benefit of utilizing the auditors to assist with the preparation of the financial statements. Views of Responsible Official: The Organization will implement controls to ensure material adjustments are posted prior to the audit. Additionally, the Organization will utilize the auditors to assist with the preparation of the financial statements prior to the audit. Any adjustments necessary for 2022 have been corrected as of the time of the audit completion with guidance from the auditors.
Criteria: The assignment of responsibilities should be segregated so that one person is not responsible for the authorization and recording of a transaction and the custody of the related asset. There needs to be a reconciliation or control activity to provide reasonable assurance that transactions are handled appropriately. Condition: Key duties and functions are not segregated among Organization personnel. Specifically, duties should be segregated to serve as a check and balance, those with access to the accounting system should not be a bank account signor. Cause: There are a limited number of personnel for certain functions. Effect or Potential Effect: The potential effect could be collusion, or material fraud. Questioned Costs: None. Recommendation: Key duties in the control environment should be segregated as much as possible, specifically we would recommend ensuring that bank signature authority be restricted to individuals with no access to the accounting system. Views of Responsible Official: The Organization is aware of the limited segregation of duties and will review internal controls and make the following changes: The Organization will contact the bank to have account access to view transactions only and remove any persons with access to the accounting system as an account signor.
Information on the Federal Program: Assistance Listing Number 16.575?Crime Victim Assistance, United States Department of Justice. Pass-Through Entity: Colorado Department of Public Safety. Award Number: 2020-VA-21-562-02. Compliance Requirements: Allowable Costs Type of Finding Noncompliance and significant deficiency. Criteria: The Modified Total Direct Cost (MTDC) base, which is used to calculate the de minimis indirect cost rate, requires that payments over the grant period to contractors in excess of $25,000, be backed out of the MTDC base. Condition: In the third quarter of 2022, we identified an error in the MTDC, where payments to contractors in excess of $25,000 were not backed out properly. Context: One of the four quarters calculation of the indirect cost rate was found to have an error. Cause: There are a limited number of personnel to ensure adequate review is performed, prior to submitting quarterly reimbursements under the grant. Effect or Potential Effect: The Organization may be out of compliance with the terms and conditions of the grant. Questioned Costs: $1,020 Recommendation: The Organization should have controls in place to ensure a more robust review of quarterly reimbursements are performed, including the accuracy of the MTDC base used to calculate indirect costs. Views of Responsible Official: The Organization has hired a full-time Finance Director who will monitor these matters more closely than under the previous structure. The Organization will also review the current controls to ensure a more robust review of quarterly reimbursements are performed The organization will review policies and implement an action plan based on the availability of limited staff.
Information on the Federal Program: Assistance Listing Number 16.575?Crime Victim Assistance, United States Department of Justice. Pass-Through Entity: Colorado Department of Public Safety. Award Number: 2020-VA-21-562-02. Compliance Requirements: Allowable Costs Type of Finding Noncompliance and significant deficiency. Criteria: In accordance with the terms and conditions of the grant agreement, employee wages may be reimbursed for allowable costs up to a stated percentage. The quarterly draws submitted to the Colorado Department of Public Safety should be equal to, or document, any variances from the stated salary percentages allowed. Condition: We identified inconsistencies between the allocation of wages submitted for reimbursement to the Colorado Department of Public Safety, and what was allowed per the budget under the terms and conditions of the grant. Context: Out of our sample of 10 quarterly wages submitted for reimbursement, 3 employees were reimbursed at a higher percentage than was allowable under the terms and conditions of the grant. Time records were available to support the amount charged to the grant, but were not in accordance with the terms and conditions of the grant. The differences were not identified or supported in the submission for reimbursement. Controls did not appear to be operating effectively to prevent or detect the discrepancy between the approved grant budget and the wages charged to reimbursement. Cause: There are a limited number of personnel to ensure adequate review is performed, prior to submitting quarterly reimbursements under the grant. Effect or Potential Effect: The Organization may be out of compliance with the terms and conditions of the grant. Questioned Costs: None. Recommendation: The Organization should have controls in place to ensure a more robust review of quarterly reimbursements are performed, and document any variances from the allowed wages in the grant agreement, and what is being submitted for reimbursement. Views of Responsible Official: The Organization has hired a full-time Finance Director who will monitor these matters more closely than under the previous structure. The Organization will also review the current controls to ensure a more robust review of quarterly reimbursements are performed and will document any variances from the allowed wages in the grant agreement, and what is being submitted for reimbursement. The organization will review policies and implement an action plan based on the availability of limited staff.
Information on the Federal Program: Assistance Listing Number 16.575?Crime Victim Assistance, United States Department of Justice. Pass-Through Entity: Colorado Department of Public Safety. Award Number: 2020-VA-21-562-02. Compliance Requirements: Allowable Costs Type of Finding Noncompliance and significant deficiency. Criteria: As outlined in the Department of Justice Financial Guide, all grant recipients are required to complete and keep on file the U.S. Citizenship and Immigration Services? Employment Eligibility Verification Form I-9 for individuals working under the award. Condition: We were unable to obtained a completed I-9 for one employee working under the award. Context: Out of our sample of 9 employees, we were unable to obtain and I-9 for 1 employee. Cause: Employee was hired during the Covid-19 pandemic, the I-9 was overlooked as the hiring process was completed virtually. Effect or Potential Effect: Failure to obtain I-9?s as required may result in ineligible employees being permitted to work on the aware. This is considered material non-compliance with the grant agreement.Questioned Costs: None. Recommendation: The Organization should have a new hire checklist, that includes a I-9 is completed for each employee that is working under Department of Justice grant funding. Additionally, the Organization should review controls to ensure I-9?s for all employees are obtained and maintained. Views of Responsible Official: Once Project Safeguard realized that the organization didn?t have a copy of the file from the Board of Directors from the Executive Director having been hired in 2013, Project Safeguard has rectified the situation by replacing the missing I-9 with an updated I-9 with attestation in accordance to guidance from UCIS . All I-9s are completed and maintained in a separate file as soon as employment begins and E-verify is completed within three days of employment as stated in the Project Safeguard policies.
Criteria: The preparation of the financial statements and the related notes are the responsibility of management. Condition: Auditor is required to report on whether the Organization is able to prepare financial statements in accordance with GAAP. The preparation of financial statements in accordance with GAAP requires internal controls over both 1) recording, processing, and summarizing accounting data, and 2) the presentation of the organization?s financial statements, disclosures, supplementary information, schedule of federal and state financial assistance in conformity with generally accepted accounting principles (GAAP) of the United States. Internal control system does not include a process for preparing the annual financial statements and related disclosures in accordance with GAAP. The Organization?s ability to prepare financial statements in accordance with GAAP is based, in part, on its reliance on its external auditors, who cannot by definition be considered part of the Organization?s internal controls. Material adjustments were required to present the statements in accordance with GAAP. Cause: There are a limited number of office employees and resources available to allow for adequate preparation of the financial statements. Effect or Potential Effect: Potential for undetected errors, or material misstatements. Specifically adjustments related to investments, in-kind contributions and the recording of right to use assets in accordance with 842, were posted in order to present the statements in accordance with GAAP. Completeness of the financial statement disclosures and accuracy of the overall financial presentation are negatively impacted as outside auditors do not have the same comprehensive understanding of the Organization as its internal financial staff.Questioned Costs: None. Recommendation: The Organization should implement controls to ensure material adjustments are posted prior to the audit. Additionally, the Organization should continue to review the cost/benefit of utilizing the auditors to assist with the preparation of the financial statements. Views of Responsible Official: The Organization will implement controls to ensure material adjustments are posted prior to the audit. Additionally, the Organization will utilize the auditors to assist with the preparation of the financial statements prior to the audit. Any adjustments necessary for 2022 have been corrected as of the time of the audit completion with guidance from the auditors.
Criteria: The assignment of responsibilities should be segregated so that one person is not responsible for the authorization and recording of a transaction and the custody of the related asset. There needs to be a reconciliation or control activity to provide reasonable assurance that transactions are handled appropriately. Condition: Key duties and functions are not segregated among Organization personnel. Specifically, duties should be segregated to serve as a check and balance, those with access to the accounting system should not be a bank account signor. Cause: There are a limited number of personnel for certain functions. Effect or Potential Effect: The potential effect could be collusion, or material fraud. Questioned Costs: None. Recommendation: Key duties in the control environment should be segregated as much as possible, specifically we would recommend ensuring that bank signature authority be restricted to individuals with no access to the accounting system. Views of Responsible Official: The Organization is aware of the limited segregation of duties and will review internal controls and make the following changes: The Organization will contact the bank to have account access to view transactions only and remove any persons with access to the accounting system as an account signor.