Type of Finding: Significant Deficiency in Internal Control Over Compliance – Cash Management and Reporting Recommendation: The Organization should formalize and consistently apply its review and approval controls over drawdown requests and grant reports. Management should review all submissions pri...
Type of Finding: Significant Deficiency in Internal Control Over Compliance – Cash Management and Reporting Recommendation: The Organization should formalize and consistently apply its review and approval controls over drawdown requests and grant reports. Management should review all submissions prior to filing and maintain documentation evidencing the review and approval performed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This finding is a repeat of prior-year finding 2024-002. The Organization implemented its documented review and approval process over federal drawdown requests in September 2025. As noted in the finding, the two drawdown requests without documented review were submitted prior to that implementation, and the remaining drawdown requests tested included documented review and approval. Building on the corrective action plan submitted for fiscal year 2024, the Organization has taken the following corrective actions: ● Beginning in September 2025, the Organization implemented a documented two-level review and approval process for all federal drawdown requests. The preparer compiles the supporting documentation, and the Operations Director reviews the request and provides written approval prior to submission. ● Documented management review and approval has been extended to ETA-9130 financial reports, which are reviewed and approved by the Operations Director prior to filing. ● The Organization's Cash Management Policy was formally updated, effective March 3, 2026, as part of the corrective action plan submitted to and approved by the U.S. Department of Labor. The policy requires written management approval prior to submission of any drawdown request, documented management review of ETA-9130 financial reports prior to filing, and retention of all approval evidence in the electronic grant file, memorializing the drawdown review procedures in practice since September 2025. ● No drawdown request or financial report is submitted until the Operations Director's written approval has been received and saved to the electronic grant file, so evidence of review and approval is retained for every submission. ● The Operations Director will conduct quarterly internal reviews to ensure this process is being followed. The drawdown review and approval process has been in practice since September 2025, and the review and approval requirements for drawdown requests and financial reports were formally documented in policy effective March 3, 2026. These controls continue to be monitored on an ongoing basis to prevent recurrence. Name(s) of contact person(s) responsible for corrective action: Cory Finley, Operations Director, with oversight by Brandi Jahnke, Chief Executive Officer Planned completion date for corrective action plan: Drawdown review and approval implemented in practice as of September 2025; review and approval requirements formalized in written policy effective March 3, 2026. The Operations Director will conduct quarterly internal reviews on an ongoing basis. If the U.S. Department of Labor has questions regarding this plan, please call Brandi Jahnke at (816) 520-4404.