April 24, 2025
Appalachian Community Capital Corporation respectfully submits the following corrective action plan for the year ended December 31, 2024.
Name and address of independent public accounting firm:
Brown, Edwards & Company, L.L.P.
105 Arbor Drive, 3rd Floor
Christiansburg, VA 24073
Aud...
April 24, 2025
Appalachian Community Capital Corporation respectfully submits the following corrective action plan for the year ended December 31, 2024.
Name and address of independent public accounting firm:
Brown, Edwards & Company, L.L.P.
105 Arbor Drive, 3rd Floor
Christiansburg, VA 24073
Audit period: December 31, 2024
The findings from the December 31, 2024 Schedule of Findings and Questioned Costs (the “Schedule”) are discussed below. The findings are numbered consistently with the number assigned in the Schedule.
FINDINGS – FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT
2024-001: Environmental Protection Agency – Assistance Listing No. 66.960, Greenhouse Gas Reduction Fund: Clean Communities Investment Accelerator, Significant Deficiency
Criteria and Condition: Recipients of federal funds are required to prepare a complete and accurate Schedule of Expenditures of Federal Awards. Additionally, recipients must establish and maintain effective internal controls over federal awards to provide reasonable assurance of accurate financial reporting
Context: The Company updated the 2024 Schedule of Expenditures of Federal Awards by a material amount a result of issues identified during review of subsequent disbursements in the financial statement audit.
Cause: The error occurred due to insufficient controls over the process for capturing and reconciling all expenditures incurred during the period to be included on the SEFA.
Effect: The SEFA initially provided understated total federal expenditures and excluded a material portion of major program activity.
Recommendation: We recommend that the Company implement enhanced SEFA preparation and review procedures, including a reconciliation of SEFA amounts to general ledger activity and verification that all applicable federal awards are included.
Views of Responsible Officials and Planned Corrective Actions: The SEFA was reconciled with the general ledger accounts and the understatement was caused by the delay in receipt and payment of several invoices that were not captured on the general ledger for the year. The exclusion of these invoices was due to a meticulous contract and invoicing compliance review of vendors by the grant team to ensure compliance with the grant terms and conditions. This review process often involved the need for vendors to revise and resubmit invoices, and in some cases, this compliance review delayed the presentation of invoices to the accounts payable team. Since then, we have developed invoicing best practices and training for all vendors to improve their ability to present compliant invoices in a timely manner.
We agree the SEFA was understated and have established new processes to ensure all expenditures are properly included in the SEFA by adding another layer of review by the personnel responsible for all expenditure approval and reporting of the major program and an enhanced review of invoices paid after the period end. As part of this enhanced review, we will cross-check data maintained in the Grant Tracker workbook which tracks all invoices associated with program administration of the grant as a related source of documentation for the SEFA preparation.
Name of Contact Person: Donna Gambrell, President and Chief Executive Officer
Signature of Contact Person: