Views of Responsible Officials and Planned Corrective Action: Management acknowledges that, for certain reimbursement requests, documentation evidencing review and approval prior to submission was not retained. Management notes, however, that the underlying expenditures included in the reimbursement...
Views of Responsible Officials and Planned Corrective Action: Management acknowledges that, for certain reimbursement requests, documentation evidencing review and approval prior to submission was not retained. Management notes, however, that the underlying expenditures included in the reimbursement requests were valid, properly recorded in the general ledger, and supported by appropriate accounting records. No questioned costs were identified, and the amounts requested for reimbursement were consistent with allowable program expenditures. Management believes the condition was limited to documentation of review rather than the absence of an actual review process. Reimbursement requests were prepared using underlying financial records and submitted based on incurred costs; however, evidence of supervisory review was not consistently retained during a period of staffing transition. Upon identification, management evaluated its cash management and drawdown processes and reinforced expectations related to documentation and retention of review and approval. Review and approval of reimbursement requests are now consistently evidenced through electronic or physical sign off, and supporting documentation is maintained in a centralized and accessible manner. In addition, management has reinforced alignment of drawdown activity with underlying accounting records to ensure consistency between reimbursement requests, financial reporting, and the general ledger. Management believes this condition represents a documentation gap during a defined period rather than a systemic breakdown in internal control over compliance. The underlying control activities—preparation of drawdowns based on recorded expenditures and supervisory oversight—were in place and functioning, and the enhancements implemented ensure consistent documentation and retention of those controls going forward. Management will continue to monitor these processes as part of ongoing financial operations to ensure compliance with applicable requirements, including 2 CFR Part 200. Management respectfully notes that this condition was limited to the retention of documentation evidencing review and approval and did not impact the allowability of costs, the accuracy of reimbursement requests, or compliance with program requirements. All expenditures were properly supported and recorded, and no questioned costs were identified.