Finding 2022-003: Internal Controls and Compliance over Reporting (Significant Deficiency)
Conditions: The Organization did not submit the quarterly reports within the specified time frame in accordance with the HIAS agreements.
Additionally, the Organization did not comply with the required sub...
Finding 2022-003: Internal Controls and Compliance over Reporting (Significant Deficiency)
Conditions: The Organization did not submit the quarterly reports within the specified time frame in accordance with the HIAS agreements.
Additionally, the Organization did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ending June 30, 2022. The Organization was not in compliance with the reporting requirements, federal regulations, and guidelines.
Effect: The Organization was not in compliance with the reporting requirements, federal regulations, and guidelines, and it could be exposed to a reduction or elimination of funds by the federal awarding agencies.
Auditor's Recommendation:
JFSSV recommends that the Organization evaluate its policies and procedures regarding report submission to ensure the timely submission of all compliance reports. In addition, the Organization should maintain documentation to support the appropriate and timely submission of the single audit (SF-SAC form).
Management Response:
We agree with the recommendation and have also submitted the following response: According to the HIAS agreement, the following reporting deadlines are specified for HIAS to their funder PRM:
Programmatic and Financial Reporting Deadlines:
· HIAS must submit performance and financial reports to PRM thirty (30) days after the end of each reporting period and in accordance with the schedule outlined by PRM.
· HIAS must also submit a final program and financial report ninety (90) calendar days after the period of performance end date.
To ensure timely submission of the foregoing reports to PRM, the Agency “HIAS” shall submit performance and financial reports to HIAS as follows:
Programmatic Reports:
The Agency will file monthly R&P Period reports through the IRIS database, as well
as other programmatic reports as requested by HIAS.
Financial Reports:
The Agency agrees to submit financial reports monthly on or before the 15th day of the following month after the books have closed. Financial reports must be submitted using the Arrivals and Expenditure Workbook provided by HIAS. HIAS agrees to make payments on these financial reports on or before the 25th day of the month for invoices submitted on or before the 15th day of the month.
To ensure HIAS stays in compliance, JFSSV makes every effort to submit accurate reports on
time. Funder HIAS agreed in an email sent to the auditors that invoice submission after the 15th is acceptable. As a result, the organization has never been denied reimbursement funding.
Some of the delays with invoice submission were due to the following reasons:
· When the 15th falls on a weekend (or Friday) or a company and Jewish holidays.
· Additional effort to compile client and expense information due to volume and complexity.
· The templates required for reporting and reimbursement have not yet been established.
· Budget revisions.
Furthermore, consultation reports are not considered "submitted" until they receive approval from HIAS. This process ensures no corrections, and the report is finalized and meets the requirements of HIAS reporting. It can take a few days to review and clarify any questions HIAS may have.
JFSSV has presented Harshwal & Company LLP with funder approval on late filings and documentation of reporting submission.
To address the specific concerns raised regarding internal controls over compliance and reporting, JFSSV will:
Evaluate and Update Policies and Procedures: JFSSV will review HIAS-approved Policies and procedures and ensure documentation on any late invoices due to the items listed above.
Enhance Communication and Coordination: JFSSV will continue to communicate and coordinate with HIAS to ensure the timely approval of consultation reports and to clarify any issues promptly.
Maintain Comprehensive Documentation: JFSSV will maintain comprehensive documentation to support the submission of the single audit (SF-SAC form) and other compliance reports. JFSSV agrees with the delay in completing the FY22 audit. The unforeseen necessity for an additional auditor, which came to light during the initial audit process, significantly impacted JFSSV's timeline. Although this presented an unexpected challenge, JFSSV swiftly engaged a new auditing firm to restart the audit. Additionally, to ensure efficiency and accuracy moving forward, JFSSV made the decision to transfer our outsourcing accounting department. Furthermore, JFSSV is taking proactive measures to streamline its processes for future audits, with the aim of achieving faster turnarounds and compliance with reporting requirements, federal regulations, and guidelines.
JFSSV is committed to maintaining and improving its financial and operational controls. We will monitor corrective actions and adjust our procedures as necessary to prevent similar issues in the future.