The Center for Advanced Defense Studies (C4ADS) acknowledges the finding related to disbursement approvals and the instance where required pre-disbursement authorization was not documented in the system. Existing C4ADS policy requires the approval of the budget manager before finance team approval o...
The Center for Advanced Defense Studies (C4ADS) acknowledges the finding related to disbursement approvals and the instance where required pre-disbursement authorization was not documented in the system. Existing C4ADS policy requires the approval of the budget manager before finance team approval on all credit card transactions — this sequence ensures that someone with operational authority verifies necessity and project relevance before charges are recorded. The accounting manager, as the administrator of the credit card online portal, has the ability to override/approve out of sequence with approval from the Senior Director of Operations. Due to staff turnover, the accounting manager inadvertently approved a charge out of cycle. Divvy does not permit retroactive correction of approval order and the accounting manager failed to appropriately document the event. As a result of this finding, C4ADS has implemented the following corrective actions: ● Strengthen Approval Controls: C4ADS added an additional review step where the Director of Finance and the Senior Director of Operations review all credit card charges to ensure all charges have two approvers. In cases where the charge has one approver, the Director of Finance confirms with the Senior Director of Operations that the final coding is appropriate prior month ending billing and month end reporting. ● Enhance Documentation and Monitoring: To demonstrate review, the Director of Finance communicates any anomalies to the Senior Director of Operations via Monday.com, C4ADS’ online ticket and tracking system. The Senior Director of Operations approval, or rejection, is logged in that system. ● Staff Training and Reinforcement: Additional training has been provided to the accounting department related to the approval override system and the appropriate documentation. These measures have been implemented and incorporated into ongoing financial processes to ensure all disbursements are properly authorized and documented.