Finding 2023-002 - Source Documentation (Significant Deficiency)
CFDA Title and Number: 20.513 (5310) Enhanced Mobility of Seniors and Individuals with Disabilities.
Name of Federal Agency: Transit Services Program Cluster
Internal Control over Compliance: Cash Management
CFDA Title and Number: 20...
Finding 2023-002 - Source Documentation (Significant Deficiency)
CFDA Title and Number: 20.513 (5310) Enhanced Mobility of Seniors and Individuals with Disabilities.
Name of Federal Agency: Transit Services Program Cluster
Internal Control over Compliance: Cash Management
CFDA Title and Number: 20.509 (5311) CARES 5311 Operating Assistance. Formula Grants for Rural.
Name of Federal Agency: Transit Services Program Cluster
Internal Control over Compliance: Cash Management
Criteria: 2 CFR Part 200.302(b)(1) The financial management system of each non-federal entity must provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. 200.302(b)(2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in 200.328 and 200.329.
Condition: The District prepared reimbursement calculations according to an internally developed spreadsheet tool, rather than using amounts directly obtained from the general ledger and supporting documentation.
Cause: General ledger data used to prepare spreadsheets, then used to complete reimbursement requests added unnecessary complexity and potential for errors in the reimbursement and request and grant reporting process. Internal control procedures assuring accurate and timely review of reports and filing of the reimbursement requests were not designed or implemented.
Effect or Potential Effect: The lack of effective internal control activities over financial reporting could allow for inadvertent errors, such as calculation errors, payments for unauthorized purposes, and result in improper grant accounting, reporting, and reimbursement.
Questioned Cost: No
Context: Internal disputes regarding grant reimbursement request procedures were evident. The weak or nonexistent controls over the reimbursement request procedures created a potential for inaccurate, incomplete reporting.
Repeat of a Prior-Year Finding: Yes, Findings and Questioned Costs 2022-003
Recommendation: The District should continue to improve grant accounting efforts, and establish a more simplified and effective process for the review and approval of grant accounting and reimbursement requests. Additional training of management should occur to ensure they fully understand all compliance regulations and have the skills to assist in designing and implementing effective controls. Monitoring of the control procedures related to the grant accounting and reimbursement request should be performed regularly to ensure reports are filed accurately and timely. Information and communication regarding identified weaknesses and opportunities to improve the policies and procedures should occur among management and the individual performing the monitoring of the procedures.
District's Response: The District’s Finance Manager and District Manager are working towards using general ledger reporting exclusively for reimbursement request reporting. General ledger activity became more timely as improvements were implemented based on prior year findings. Management acknowledges delays in that process that continued as a result, to some extent, of the use of the self-developed spreadsheet reports then used for completing grant reimbursement requests.
Corrective Action Plan: The District’s Finance Manager will continue to make improvements in general ledger recording and reporting systems so that those reports can then be used without intermediary report methods to prepare reimbursement request forms. Review of the reimbursement requests will take place within data reports generated directly from the general ledger. The district will engage an individual or firm to ensure that the timing and overall processes related to grant reimbursement and reporting does not result in reporting errors or omissions.
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Planned Implementation Date: September 30, 2024
Responsible Person: General Manager, Umpqua Public Transit District