Response and Views of Responsible Officials Management acknowledges the finding related to the design and operating effectiveness of internal controls over compliance for the MIECHV program. While key review processes were generally in place, the organization recognizes that controls were not consis...
Response and Views of Responsible Officials Management acknowledges the finding related to the design and operating effectiveness of internal controls over compliance for the MIECHV program. While key review processes were generally in place, the organization recognizes that controls were not consistently documented or demonstrated during the audit period. In addition, documentation supporting expenditure approvals, grant coding, reimbursement preparation, supervisory review, and retention of supporting records was not consistently maintained. As a result, the auditors were unable to rely on the organization's internal controls to reduce the risk of noncompliance. The organization has taken the following corrective actions: • Adopted comprehensive Financial Policies and Procedures and Accounting Policies that clearly define internal controls over purchasing, cash disbursements, payroll, grant management, documentation retention, segregation of duties, supervisory review, and financial reporting. • Implemented written procedures outlining the authorization, coding, allocation, reimbursement, and documentation requirements for grant-funded expenditures. • Adopted a formal Cost Allocation Plan that documents the methodology for allocating shared costs and grant expenditures. • Assigned responsibility for independent review of reimbursement requests prior to submission. Reimbursement requests are now prepared by program management and reviewed by the internal bookkeeper before submission whenever practicable. • Established standardized documentation requirements to retain supporting invoices, approvals, allocation documentation, reimbursement support, and evidence of supervisory review within organized grant files. • Established procedures requiring documentation of management review through signatures, initials, electronic approvals, or other evidence demonstrating that required reviews were completed. To further strengthen internal controls and ensure continued compliance, the organization will: • Develop standardized internal review checklists for reimbursement requests and other key grant compliance activities to document preparation, supervisory review, and approval. • Conduct periodic internal monitoring to verify that established procedures are operating consistently and that supporting documentation is complete. • Provide training to staff responsible for grant administration and financial management regarding internal control responsibilities, documentation expectations, and federal compliance requirements. • Incorporate periodic management review of grant files to verify that expenditures, approvals, reimbursement documentation, and supporting records are complete and retained in accordance with organizational policies. Responsible Official: Josie Brittain Anticipated Completion Date: September 30, 2026