SECTION III – FINDINGS – FEDERAL AWARD FINDINGS
Finding 2023-001 – Activities Allowed/Unallowed, Costs Principles, and Period of
Performance (Internal Controls Over Compliance)
Significant Deficiency
Criteria:
Uniform Guidance 2 CFR, Part §200.313(a) requires that non-federal entities must establish...
SECTION III – FINDINGS – FEDERAL AWARD FINDINGS
Finding 2023-001 – Activities Allowed/Unallowed, Costs Principles, and Period of
Performance (Internal Controls Over Compliance)
Significant Deficiency
Criteria:
Uniform Guidance 2 CFR, Part §200.313(a) requires that non-federal entities 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).
Condition:
During our review of the Coalition’s disbursements related to the Title V major program, we
examined 40 transactions for internal controls over compliance. 2 of the 40 transactions examined
did not contain sufficient evidence that a review and approval process was completed prior to
payment being processed.
Questioned Costs:
None
Cause:
The Coalition does not have sufficiently established control policies and procedures to ensure
proper approvals are obtained prior to the disbursement transactions being processed.
Effect:
Disbursements are being processed without proper approval, resulting in the possibility of
disallowed expenditures.
SECTION III – FINDINGS – FEDERAL AWARD FINDINGS
Finding 2023-001 – Activities Allowed/Unallowed, Costs Principles, and Period of
Performance (Internal Controls Over Compliance), continued
Recommendation:
We recommend the Coalition becomes familiar with requirements of 2 CFR, Part §200.313(a) and
establishes appropriate internal control policies and procedures and that all staff be trained on
those policies and procedures, so they are familiar with the requirements. We further recommend
the Coalition does not process payment for disbursements that do not contain necessary
approvals.
Responsible Official: Carlett Gregory, CFO
Corrective Action: In response to the finding regarding insufficient internal controls over compliance for disbursements related to the Title V major program, the Coalition will take the following corrective actions:
1. Review and Revise Policies and Procedures:
o The Coalition will conduct a thorough review of our current internal control policies and procedures related to disbursements to ensure they align with the requirements of 2 CFR, Part §200.313(a).
o We will revise and update our policies and procedures as necessary to ensure they are comprehensive and robust, providing clear guidelines for review and approval processes.
2. Training and Education:
o We will provide additional training to all staff involved in the procurement process to ensure they are fully aware of the updated policies and procedures.
o The training will cover the importance of obtaining proper approvals prior to processing payments and the specific requirements of 2 CFR, Part §200.313(a).
3. Implementation of Approval Controls:
o We have implemented a standardized approval process for all disbursements, ensuring that each transaction is reviewed and approved by the designated authority before payment is processed.
o We currently have in place a checklist to document the review and approval process for each transaction, ensuring that evidence of compliance is retained.
4. Monitoring and Compliance Checks:
o We will establish regular monitoring and compliance checks to ensure adherence to the updated policies and procedures.
o Quarterly internal audits will be conducted to verify that all disbursements are properly reviewed and approved according to the established guidelines.
Timeline for Implementation: The corrective actions outlined above have been implemented. Training sessions will be part of the onboarding process and existing programs. It will also be reviewed as needed to address any changes.