Audit 54852

Federal Agency: Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Listing Number: 21.027 Federal Award Identification Number and Year: Pass-Through Agency: Connecticut Bar Foundation Pass-Through Number: CT-RTC Award Period: 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Organization must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition: The procurement policy and conflict of interest policy of the Organization do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None Context: We reviewed the procurement policy and conflict of interest policy of the Organization and noted that the policies do not include the essential compliance elements as outlined in 2 CFR sections 200.318 through 200.326. Cause: Management was unaware of the restrictive requirements of the new procurement standards. Effect: With the absence of a compliant policy, the Organization is at risk for noncompliance as it relates to federal procurement. Repeat Finding: No Recommendation: We recommend that the Organization review its procurement policy and conflict of interest policy and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Listing Number: 21.027 Federal Award Identification Number and Year: Pass-Through Agency: Connecticut Bar Foundation Pass-Through Number: CT-RTC Award Period: 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: Payroll costs must be supported with time and effort documentation in accordance with the Uniform Guidance (2 CFR Part 200). Condition: Payroll costs for one of the employees were not supported with time and effort documentation in accordance with the Uniform Guidance (2 CFR Part 200). Questioned costs: None Context: During testing of payroll disbursements, we noted one employee who is 50% funded by the grant. We reviewed her weekly timesheet noting that the hours charged to the grant are not tracked and there are no other records retained documenting that 50% of her time is spent towards the grant. Cause: Management was unaware of time and effort documentation as required by Uniform Guidance (2 CFR Part 200). Effect: The Organization is at risk for noncompliance as it relates to allowable costs/costs principles. Repeat Finding: No Recommendation: We recommend that the Organization retain records to satisfy the time and effort documentation as required by Uniform Guidance (2 CFR Part 200). Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Listing Number: 21.027 Federal Award Identification Number and Year: Pass-Through Agency: Connecticut Bar Foundation Pass-Through Number: CT-RTC Award Period: 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Organization must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition: The procurement policy and conflict of interest policy of the Organization do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None Context: We reviewed the procurement policy and conflict of interest policy of the Organization and noted that the policies do not include the essential compliance elements as outlined in 2 CFR sections 200.318 through 200.326. Cause: Management was unaware of the restrictive requirements of the new procurement standards. Effect: With the absence of a compliant policy, the Organization is at risk for noncompliance as it relates to federal procurement. Repeat Finding: No Recommendation: We recommend that the Organization review its procurement policy and conflict of interest policy and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Listing Number: 21.027 Federal Award Identification Number and Year: Pass-Through Agency: Connecticut Bar Foundation Pass-Through Number: CT-RTC Award Period: 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: Payroll costs must be supported with time and effort documentation in accordance with the Uniform Guidance (2 CFR Part 200). Condition: Payroll costs for one of the employees were not supported with time and effort documentation in accordance with the Uniform Guidance (2 CFR Part 200). Questioned costs: None Context: During testing of payroll disbursements, we noted one employee who is 50% funded by the grant. We reviewed her weekly timesheet noting that the hours charged to the grant are not tracked and there are no other records retained documenting that 50% of her time is spent towards the grant. Cause: Management was unaware of time and effort documentation as required by Uniform Guidance (2 CFR Part 200). Effect: The Organization is at risk for noncompliance as it relates to allowable costs/costs principles. Repeat Finding: No Recommendation: We recommend that the Organization retain records to satisfy the time and effort documentation as required by Uniform Guidance (2 CFR Part 200). Views of Responsible Officials: There is no disagreement with the audit finding.