Management Response: SWIWC concurs with the auditor's finding that adequate supporting documentation was not provided during the audit for 14 of the 40 expenditure transactions selected for testing. SWIWC recognizes that federal expenditures must be supported by sufficient documentation to demonstra...
Management Response: SWIWC concurs with the auditor's finding that adequate supporting documentation was not provided during the audit for 14 of the 40 expenditure transactions selected for testing. SWIWC recognizes that federal expenditures must be supported by sufficient documentation to demonstrate that costs were authorized, incurred for an allowable program purpose, properly allocated to the award, and adequately supported by underlying source documentation. SWIWC respectfully distinguishes, however, between a cost that is questioned because sufficient documentation was not available during the audit and a cost that has been affirmatively determined to be unallowable. The $70,587 reported as questioned costs relates to transactions for which the documentation provided during audit testing was considered insufficient. The finding does not state that the auditors determined that the underlying goods or services were not received, that the expenditures were outside the objectives of the award, or that the expenditures were otherwise affirmatively determined to be unallowable. Corrective Actions Implemented Since the FY2023 period under audit, SWIWC has strengthened its expenditure-processing and documentation controls. SWIWC requires expenditure transactions to be supported by documentation appropriate to the nature of the transaction, which may include invoices, receipts, contracts, agreements, travel documentation, purchasing documentation, evidence of receipt of goods or services, and evidence of required approval. Finance reviews transactions for appropriate funding source, supporting documentation, authorization, and consistency with applicable grant and organizational requirements. SWIWC has strengthened its accounts payable procedures so that supporting documentation is associated with the corresponding accounting transaction and maintained electronically. Documentation deficiencies identified during processing or subsequent review are followed up with the responsible employee or program before the transaction is considered fully documented. SWIWC has also strengthened grant expenditure monitoring through budget-to-actual review and centralized grant records. Grant and financial documentation is maintained in a manner designed to permit transactions to be traced from the accounting records to the underlying supporting documentation and, where applicable, to grant reporting and reimbursement records. Preventive Controls To prevent recurrence, SWIWC has implemented or strengthened the following controls: • Standardized expenditure documentation requirements; • Documented review and approval of expenditures; • Centralized electronic retention of supporting records; • Identification of the applicable funding source; • Review of expenditures for grant allowability and allocability; • Procurement documentation requirements; • SAM.gov verification when applicable; • Budget-to-actual grant monitoring; • Periodic Finance review of supporting documentation; • Staff training regarding expenditure and grant-documentation requirements in February 2026; and • Maintenance of records in an audit-ready format to be completed by 9/30/2026. Resolution of Questioned Costs SWIWC understands that the ultimate resolution of questioned costs rests with the applicable awarding or pass-through entity through the audit-resolution process. SWIWC will therefore maintain the $70,587 as questioned costs pending completion of the applicable resolution process and will not characterize the entire amount as either allowable or unallowable solely on the basis of the audit finding. For transactions for which sufficient supporting documentation is identified or reconstructed, SWIWC will provide that documentation as appropriate to support resolution of the questioned amount. If the awarding or pass-through entity ultimately determines that any portion of the questioned costs is unallowable, SWIWC will take the corrective action required by that determination, including repayment or other financial adjustment if required. Anticipated Completion Date: September 30, 2026, for completion of the historical transaction review; enhanced expenditure controls are currently in effect and will continue on an ongoing basis. Responsible Party: Chief Financial Officer and Director of Finance, with applicable Program Managers responsible for providing programmatic documentation.