CORRECTIVE ACTION PLAN
Summary Schedule of Current Year Audit Findings
In accordance with Title 2 CFR 200 Uniform Administrative Requirements, Cost Principles and
Audit Requirements under Section 200.511, Audit Findings follow-up, the following detail the
summary of current year audit findings (and ...
CORRECTIVE ACTION PLAN
Summary Schedule of Current Year Audit Findings
In accordance with Title 2 CFR 200 Uniform Administrative Requirements, Cost Principles and
Audit Requirements under Section 200.511, Audit Findings follow-up, the following detail the
summary of current year audit findings (and the related corrective action plan) is presented below:
Finding 2023-001: Inadequate Financial Reporting
Condition: The tracking of eligible (billable) costs within the accounting system was inadequate
and required a significant amount of work to generate reconciliations of billable costs to contract
billings. In additional certain grants were inconsistently reflected as restricted or conditional
compared to similar grants. As part of the process to review year end, management identified errors
which required adjustments, the most common of which was adjusting revenue between restricted
and conditional revenue.
Criteria: CFR 200.303, Internal Controls, states that 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).
Additionally, management is responsible for the preparation and fair presentation of the financial
statements in accordance with accounting principles generally accepted in the United States of
America; this includes the design, implementation and maintenance of internal control relevant to
the preparation and fair presentation of financial statements that are free from material
misstatement, whether due to fraud or error.
Cause: The Organization did not have in place a formal, clear system which reconciled the billings to the funders and related eligible costs or releases related to certain restricted grants.
Effect: Significant adjustments were proposed by management during the audit, principally between conditional and restricted revenue.
Recommendation: We strongly recommend that all costs are coded directly to a contract within the accounting system and on a monthly or quarterly (at a minimum) basis there is a reconciliation of the billings between the funders and the revenue/costs related to the contracts to assure that all
costs have been capture for billings and releases from restrictions. We also recommend detailed reviews/approvals of such reconciliations be performed.
Questioned Costs: None identified.
Context: While performing initial audit procedures, we requested management to perform a reconciliation of billings and related costs and review its recording of restricted and conditional grants. During management review, errors were identified by management and requested to be corrected. The condition noted is deemed to be systemic in nature. We did not identify any misstatements during our audit once the review was completed by management.
Identification as a Repeat Finding: This is not a repeat finding.
Management Views and Corrective Action Plan: Management agrees with the finding and recommendation. The Organization implemented a new accounting system effective July 1, 2023, in which substantially all costs are now coded to respective contracts which will provide much easily generatable support for billings. Management is working with the accounting team to implement a new process as part of the monthly closing procedures in which for cost reimbursement contacts there will be a review of revenue compared to costs to ascertain that the billing is accurate and complete.
Name and Title of Responsible Official: Eos de Feminis, Interim CFO
Planned Completion Date: Completed