U.S. Department of Justice Crime Victim Assistance – Assistance #16.575 #2023-009 – Major Federal Award Finding – Cash Management Nature of Finding: Compliance Finding Cash Management and Significant Deficiency in Internal Controls over Compliance Criteria/Condition: 2 CFR 200.305 requires that non-federal entities must minimize the time elapsing between the transfer of federal funds to the non-federal entity and the subsequent disbursement of the funds by the non-federal entity for program costs. The Organization did not have proper controls in place to verify that specific vendor invoices were paid within a reasonable amount of time of requesting reimbursement for the expenditures. Questioned Costs: $2,381 Identification of How Questioned Costs Were Computed: The issues of noncompliance related to cash management was limited to one vendor that was not paid within a reasonable amount of time of being reimbursed for the costs. This was determined to be an isolated incident. Questioned costs include the two invoices that were charged to the grant for this vendor during the year ended September 30, 2023 and were not paid to the vendor within a reasonable amount of time of being reimbursed for the expenditures. Cause/Context: Controls were not in place to ensure expenditures were paid to the vendor prior to requesting reimbursements. This circumstance was determined to be an isolated incident due to the unique nature of the vendor invoices. The Organization was withholding payment to the vendor until it determined that both invoices were proper. Effect: The lack of controls could result in requests for reimbursement being submitted for unpaid expenditures. Recommendation: We recommend the Organization establish procedures and incorporate controls to review that expenditures are paid prior to submitting requests for reimbursement. Views of Responsible Officials and Planned Corrective Actions: The Organization will implement the following changes in its accounting procedures: Each month, an aged open accounts payable report will be produced as part of the month end closing. Invoices that are past due will be paid in the following batch of payments (which are typically run weekly). If it is determined that the invoice is not being paid for a valid reason, it will be removed from accounts payable at that time. #2023-010 – Major Federal Award Finding – Period of Performance Nature of Finding: Compliance Finding Period of Performance and Material Weakness in Internal Controls over Compliance Criteria/Condition: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance. The Organization did not have controls in place to verify that costs were being charged to the award in the correct period of performance. Questioned Costs: $20,790 Identification of How Questioned Costs Were Computed: A sample of 40 non-payroll expenditures totaling approximately $48,000 was selected from a population of approximately $552,000 of non-payroll expenditures. An amount of $1,817 combined from two invoices that were charged to the Crime Victim Assistance program was related to the year ending September 30, 2024 and was inappropriately charged to the grant during 2023. Questioned costs are estimated by projecting the error identified in the sample tested to the population of non-payroll expenditures of the Crime Victim Assistance program. Cause/Context: There are not proper controls in place to review invoices and assign them to the appropriate grant period. Two expenditures out of forty non-payroll related expenditures tested for the Crime Victim Assistance grant was for a contracted annual service that covered multiple performance periods but was billed in its entirety to the current fiscal year. Effect: An overstatement of expenditures for the Crime Victim Assistance grant was reported in the current year. Recommendation: We recommend procedures are established to review for proper grant period when recording transactions and creating monthly reimbursement requests. Views of Responsible Officials and Planned Corrective Actions: The Organization will implement the following changes in its accounting procedures. 1. The Staff Accountant will review the period each expenditure is related to and record the invoice to the appropriate period when entering it into accounts payable. The month and year will be noted on the invoice. 2. The CFO will review the month and year noted by the Staff Accountant prior to entry into accounts payable.
Finding 2023-001 Lack of Internal Controls over Cash Management Federal Agency: U.S. Department of the Treasury Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Assistance Listing Numbers: 21.027 Award Number: SLFRP3171/4774 Award Years: 2021 Type of Finding: Material weakness in internal control over compliance and material noncompliance. Criteria: The requirement for cash management as contained in 2 CFR 200.305, which states advanced cash payments must be used only for applicable grant programs. Condition and Context: Procedures related to cash management were inadequate to ensure that funds drawn down were not used for other grant expenditures. The Village’s cash balances for all governmental funds amounted to $3,569,292 at September 30, 2023. The unearned revenues were $3,789,475 which resulted in a shortfall of $220,183. The unearned revenue for the CSLFRF Fund was $2,941,712. Cause: Lack of internal controls over cash management. Effect: The Village requested and received advances for various federal programs to cover expenditures. Deposits were used to fund other programs of the Village. Questioned Costs: $220,183, which is the shortfall between cash and investment balances and the unearned revenue balances. Repeat Finding: This is a repeat of finding 2022-001, and since this is a repeat finding we believe this to be a systemic issue. Recommendation: We recommend that the Village monitor grant budgets and drawdowns throughout the year and ensure that program funds are not being lent or borrowed between programs in an effort to ensure that unearned revenue balances do not exceed total cash and investments. Management’s Response: Management concurs with this finding. See corrective action plan.
Under the requirements of 2 CFR section 200.305(9), interest earned in excess of $500 per year on federal cash draws must be annually remitted to the Department of Health and Human Services, Payment Management System. For ALN 19.517, the interest earned in excess of $500 of $279 was not remitted to the Department of Health and Human Services, Payment Management System for fiscal year ended September 30, 2023.
Under the requirements of 2 CFR section 200.305(9), interest earned in excess of $500 per year on federal cash draws must be annually remitted to the Department of Health and Human Services, Payment Management System. For ALN 19.517, the interest earned in excess of $500 of $279 was not remitted to the Department of Health and Human Services, Payment Management System for fiscal year ended September 30, 2023.
Under the requirements of 2 CFR section 200.305(9), interest earned in excess of $500 per year on federal cash draws must be annually remitted to the Department of Health and Human Services, Payment Management System. For ALN 19.517, the interest earned in excess of $500 of $279 was not remitted to the Department of Health and Human Services, Payment Management System for fiscal year ended September 30, 2023.
Under the requirements of 2 CFR section 200.305(9), interest earned in excess of $500 per year on federal cash draws must be annually remitted to the Department of Health and Human Services, Payment Management System. For ALN 19.517, the interest earned in excess of $500 of $279 was not remitted to the Department of Health and Human Services, Payment Management System for fiscal year ended September 30, 2023.
Under the requirements of 2 CFR section 200.305(9), interest earned in excess of $500 per year on federal cash draws must be annually remitted to the Department of Health and Human Services, Payment Management System. For ALN 19.517, the interest earned in excess of $500 of $279 was not remitted to the Department of Health and Human Services, Payment Management System for fiscal year ended September 30, 2023.
Under the requirements of 2 CFR section 200.305(9), interest earned in excess of $500 per year on federal cash draws must be annually remitted to the Department of Health and Human Services, Payment Management System. For ALN 19.517, the interest earned in excess of $500 of $279 was not remitted to the Department of Health and Human Services, Payment Management System for fiscal year ended September 30, 2023.
Under the requirements of 2 CFR 200.305 (b)(3), When the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or passthrough entity reasonably believes the request to be improper. For ALN 19.517, all selections tested of payments to subrecipients, MTI did not remit payment with federal funds timely, with time between receipt of subrecipient invoice and MTI payment ranging from 3 to 6 months. Total federal funds passed through to subrecipients is $525,953 of which $169,733 was tested.
Under the requirements of 2 CFR 200.305 (b)(3), When the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or passthrough entity reasonably believes the request to be improper. For ALN 19.517, all selections tested of payments to subrecipients, MTI did not remit payment with federal funds timely, with time between receipt of subrecipient invoice and MTI payment ranging from 3 to 6 months. Total federal funds passed through to subrecipients is $525,953 of which $169,733 was tested.
Under the requirements of 2 CFR 200.305 (b)(3), When the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or passthrough entity reasonably believes the request to be improper. For ALN 19.517, all selections tested of payments to subrecipients, MTI did not remit payment with federal funds timely, with time between receipt of subrecipient invoice and MTI payment ranging from 3 to 6 months. Total federal funds passed through to subrecipients is $525,953 of which $169,733 was tested.
Under the requirements of 2 CFR 200.305 (b)(3), When the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or passthrough entity reasonably believes the request to be improper. For ALN 19.517, all selections tested of payments to subrecipients, MTI did not remit payment with federal funds timely, with time between receipt of subrecipient invoice and MTI payment ranging from 3 to 6 months. Total federal funds passed through to subrecipients is $525,953 of which $169,733 was tested.
Under the requirements of 2 CFR 200.305 (b)(3), When the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or passthrough entity reasonably believes the request to be improper. For ALN 19.517, all selections tested of payments to subrecipients, MTI did not remit payment with federal funds timely, with time between receipt of subrecipient invoice and MTI payment ranging from 3 to 6 months. Total federal funds passed through to subrecipients is $525,953 of which $169,733 was tested.
Under the requirements of 2 CFR 200.305 (b)(3), When the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or passthrough entity reasonably believes the request to be improper. For ALN 19.517, all selections tested of payments to subrecipients, MTI did not remit payment with federal funds timely, with time between receipt of subrecipient invoice and MTI payment ranging from 3 to 6 months. Total federal funds passed through to subrecipients is $525,953 of which $169,733 was tested.
Federal Aid Policies Finding 2023-002 Condition: The Authority’s management has completely turned over and been restructured. However, the Authority’s policies for federal aid approved in 2021 have not been revised to update for the current management structure. The policies have also not been updated for changes in the 2 CFR 200 that have occurred. Criteria: The 2 CFR 200 requires the adoption of federal aid policies and that they are to be updated and maintained in accordance with the federal regulations. These policies include the following along with the 2 CFR 200 reference. a. Cash Management Procedure –200.302(b)(6) and 200.305 b. Cost Allowability Procedures –200.302(b)(7) c. Conflicts of Interest Policy –200.318(c) d. Procurement Procedures –200.318(a) and 200.319(d) e. Method for Conducting Technical Evaluations of Proposals and Selecting Recipients –200.320(b)(2)(ii) f. Travel Policy –200.475(a) g. Procedures for Managing Equipment –200.313(d) h. Employee Benefits –200.431 Cause: The Authority has experienced a high turnover of employees since 2021 when the policies were adopted and have not been reviewed since their adoption. Effect: The Authority is noncompliant with 2 CFR 200. Directive: We direct the Authority review and update all federal aid policies and implement procedures to ensure that they are being reviewed at least once a year for changes in the Authority’s management structure or changes that occur in the 2 CFR 200. Management’s Response--Corrective Action Plan: Contact person is Rufus Adams, Executive Director, 275 East Wall Street, P.O. Box 837, Benton Harbor, Michigan 49023. Telephone (269) 927-2268. The Authority will update their federal policies to comply with 2 CFR 200 and will review all policies on an annual basis going forward.
Federal Aid Policies Finding 2023-002 Condition: The Authority’s management has completely turned over and been restructured. However, the Authority’s policies for federal aid approved in 2021 have not been revised to update for the current management structure. The policies have also not been updated for changes in the 2 CFR 200 that have occurred. Criteria: The 2 CFR 200 requires the adoption of federal aid policies and that they are to be updated and maintained in accordance with the federal regulations. These policies include the following along with the 2 CFR 200 reference. a. Cash Management Procedure –200.302(b)(6) and 200.305 b. Cost Allowability Procedures –200.302(b)(7) c. Conflicts of Interest Policy –200.318(c) d. Procurement Procedures –200.318(a) and 200.319(d) e. Method for Conducting Technical Evaluations of Proposals and Selecting Recipients –200.320(b)(2)(ii) f. Travel Policy –200.475(a) g. Procedures for Managing Equipment –200.313(d) h. Employee Benefits –200.431 Cause: The Authority has experienced a high turnover of employees since 2021 when the policies were adopted and have not been reviewed since their adoption. Effect: The Authority is noncompliant with 2 CFR 200. Directive: We direct the Authority review and update all federal aid policies and implement procedures to ensure that they are being reviewed at least once a year for changes in the Authority’s management structure or changes that occur in the 2 CFR 200. Management’s Response--Corrective Action Plan: Contact person is Rufus Adams, Executive Director, 275 East Wall Street, P.O. Box 837, Benton Harbor, Michigan 49023. Telephone (269) 927-2268. The Authority will update their federal policies to comply with 2 CFR 200 and will review all policies on an annual basis going forward.
Federal Aid Policies Finding 2023-002 Condition: The Authority’s management has completely turned over and been restructured. However, the Authority’s policies for federal aid approved in 2021 have not been revised to update for the current management structure. The policies have also not been updated for changes in the 2 CFR 200 that have occurred. Criteria: The 2 CFR 200 requires the adoption of federal aid policies and that they are to be updated and maintained in accordance with the federal regulations. These policies include the following along with the 2 CFR 200 reference. a. Cash Management Procedure –200.302(b)(6) and 200.305 b. Cost Allowability Procedures –200.302(b)(7) c. Conflicts of Interest Policy –200.318(c) d. Procurement Procedures –200.318(a) and 200.319(d) e. Method for Conducting Technical Evaluations of Proposals and Selecting Recipients –200.320(b)(2)(ii) f. Travel Policy –200.475(a) g. Procedures for Managing Equipment –200.313(d) h. Employee Benefits –200.431 Cause: The Authority has experienced a high turnover of employees since 2021 when the policies were adopted and have not been reviewed since their adoption. Effect: The Authority is noncompliant with 2 CFR 200. Directive: We direct the Authority review and update all federal aid policies and implement procedures to ensure that they are being reviewed at least once a year for changes in the Authority’s management structure or changes that occur in the 2 CFR 200. Management’s Response--Corrective Action Plan: Contact person is Rufus Adams, Executive Director, 275 East Wall Street, P.O. Box 837, Benton Harbor, Michigan 49023. Telephone (269) 927-2268. The Authority will update their federal policies to comply with 2 CFR 200 and will review all policies on an annual basis going forward.
Federal Aid Policies Finding 2023-002 Condition: The Authority’s management has completely turned over and been restructured. However, the Authority’s policies for federal aid approved in 2021 have not been revised to update for the current management structure. The policies have also not been updated for changes in the 2 CFR 200 that have occurred. Criteria: The 2 CFR 200 requires the adoption of federal aid policies and that they are to be updated and maintained in accordance with the federal regulations. These policies include the following along with the 2 CFR 200 reference. a. Cash Management Procedure –200.302(b)(6) and 200.305 b. Cost Allowability Procedures –200.302(b)(7) c. Conflicts of Interest Policy –200.318(c) d. Procurement Procedures –200.318(a) and 200.319(d) e. Method for Conducting Technical Evaluations of Proposals and Selecting Recipients –200.320(b)(2)(ii) f. Travel Policy –200.475(a) g. Procedures for Managing Equipment –200.313(d) h. Employee Benefits –200.431 Cause: The Authority has experienced a high turnover of employees since 2021 when the policies were adopted and have not been reviewed since their adoption. Effect: The Authority is noncompliant with 2 CFR 200. Directive: We direct the Authority review and update all federal aid policies and implement procedures to ensure that they are being reviewed at least once a year for changes in the Authority’s management structure or changes that occur in the 2 CFR 200. Management’s Response--Corrective Action Plan: Contact person is Rufus Adams, Executive Director, 275 East Wall Street, P.O. Box 837, Benton Harbor, Michigan 49023. Telephone (269) 927-2268. The Authority will update their federal policies to comply with 2 CFR 200 and will review all policies on an annual basis going forward.
Federal Aid Policies Finding 2023-002 Condition: The Authority’s management has completely turned over and been restructured. However, the Authority’s policies for federal aid approved in 2021 have not been revised to update for the current management structure. The policies have also not been updated for changes in the 2 CFR 200 that have occurred. Criteria: The 2 CFR 200 requires the adoption of federal aid policies and that they are to be updated and maintained in accordance with the federal regulations. These policies include the following along with the 2 CFR 200 reference. a. Cash Management Procedure –200.302(b)(6) and 200.305 b. Cost Allowability Procedures –200.302(b)(7) c. Conflicts of Interest Policy –200.318(c) d. Procurement Procedures –200.318(a) and 200.319(d) e. Method for Conducting Technical Evaluations of Proposals and Selecting Recipients –200.320(b)(2)(ii) f. Travel Policy –200.475(a) g. Procedures for Managing Equipment –200.313(d) h. Employee Benefits –200.431 Cause: The Authority has experienced a high turnover of employees since 2021 when the policies were adopted and have not been reviewed since their adoption. Effect: The Authority is noncompliant with 2 CFR 200. Directive: We direct the Authority review and update all federal aid policies and implement procedures to ensure that they are being reviewed at least once a year for changes in the Authority’s management structure or changes that occur in the 2 CFR 200. Management’s Response--Corrective Action Plan: Contact person is Rufus Adams, Executive Director, 275 East Wall Street, P.O. Box 837, Benton Harbor, Michigan 49023. Telephone (269) 927-2268. The Authority will update their federal policies to comply with 2 CFR 200 and will review all policies on an annual basis going forward.
Item 2023‐002 Written policies, procedures, and standards of conduct COVID 19 – Coronavirus State and Local Fiscal Recovery Fund Assistance Listing Number 21.027 U.S. Department of Treasury Grant period: Year ended September 30, 2023 Questioned Costs – $0 Condition – The City does not have all of the written policies, procedures and standards of conduct required by UG. Criteria – 2 CFR 200.303 requires the non‐Federal entity to “(a) establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal statutes, regulations, and the terms and conditions of the Federal award.” Grantees should have written policies, procedures, and standards of conduct as required by 2 CFR 200, Subparts D & E of the Uniform Guidance. 2 CFR 200, Subparts D & E requires the non‐ Federal entity to establish and maintain written policies, procedures, and standards of conduct including internal controls over the Federal awards that provides reasonable assurance that the non‐ Federal entity is managing the Federal statutes, regulations, and the terms and conditions of the Federal award. Specific requirements relate to the following: § 200.302 Financial management § 200.305 Payment § 200.319 Competition § 200.320 Methods of procurement to be followed § 200.430 Compensation—personal services § 200.431 Compensation—fringe benefits Cause of Condition – The City has failed to prepare written policies, procedures, and standards of conduct as required by 2 CFR 200, Subparts D & E of the Uniform Guidance. Potential Effect of Condition – Lack of written policies, procedures, and standards of conduct could result in noncompliance related to federal awards. Recommendation – We recommend that the City implement the required written policies and procedures. Management’s Response – Management agrees with the finding and will implement the necessary written policies to comply with the UG. Management anticipates completion by September 30, 2024.
2023 002 Assistance Listing, Federal Agency, and Program Name ALN 10.557, U.S. Department of Agriculture, Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) Federal Award Identification Number and Year E20233413 00 (2023) and E20232456 00 (2023) Pass through Entity Michigan Department of Health and Human Services Finding Type Significant deficiency Repeat Finding No Criteria Per 2 CFR section 200.305(b)(9), interest earned amounts up to $500 per year may be retained by the non Federal entity for administrative expense. Any additional interest earned on Federal advanced payments deposited in interest bearing accounts must be remitted annually to the Department of Health and Human Services Payment Management System (PMS)t. Condition The County did not track WIC interest income earned throughout the fiscal year, resulting in the County not refunding the Department of Health and Human Services the excess of $500 earned during the year. Questioned Costs $806 Identification of How Questioned Costs Were Computed The County determined that there was $1,306 of interest earned, less $500 that can be retained for administrative expense, results in $806 that should have been remitted back to the Department of Health and Human Services. Context From October 1, 2022 through September 30, 2023, the County received advanced payments for the WIC program, which were held in an interest bearing account and those funds earned interest in excess of $500. Cause and Effect The County did not have a control in place to track the interest earned on WIC advanced payments to note if they exceeded $500 throughout the year. This resulted in the County not properly remitting the excess interest amount earned back to the Department of Health and Human Services at the end of the fiscal year. Recommendation We recommend that an internal control be put in place to monitor interest earned monthly or quarterly, to ensure that if it exceeds $500 on WIC advance payments, that it is properly remitted back to the Department of Health and Human Resources annually. Views of Responsible Officials and Planned Corrective Actions The financial analyst assigned to the grant will review interest income earned throughout the fiscal year and ensure any amount exceeding $500 is returned to the Department of Health and Human Services.
2023 002 Assistance Listing, Federal Agency, and Program Name ALN 10.557, U.S. Department of Agriculture, Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) Federal Award Identification Number and Year E20233413 00 (2023) and E20232456 00 (2023) Pass through Entity Michigan Department of Health and Human Services Finding Type Significant deficiency Repeat Finding No Criteria Per 2 CFR section 200.305(b)(9), interest earned amounts up to $500 per year may be retained by the non Federal entity for administrative expense. Any additional interest earned on Federal advanced payments deposited in interest bearing accounts must be remitted annually to the Department of Health and Human Services Payment Management System (PMS)t. Condition The County did not track WIC interest income earned throughout the fiscal year, resulting in the County not refunding the Department of Health and Human Services the excess of $500 earned during the year. Questioned Costs $806 Identification of How Questioned Costs Were Computed The County determined that there was $1,306 of interest earned, less $500 that can be retained for administrative expense, results in $806 that should have been remitted back to the Department of Health and Human Services. Context From October 1, 2022 through September 30, 2023, the County received advanced payments for the WIC program, which were held in an interest bearing account and those funds earned interest in excess of $500. Cause and Effect The County did not have a control in place to track the interest earned on WIC advanced payments to note if they exceeded $500 throughout the year. This resulted in the County not properly remitting the excess interest amount earned back to the Department of Health and Human Services at the end of the fiscal year. Recommendation We recommend that an internal control be put in place to monitor interest earned monthly or quarterly, to ensure that if it exceeds $500 on WIC advance payments, that it is properly remitted back to the Department of Health and Human Resources annually. Views of Responsible Officials and Planned Corrective Actions The financial analyst assigned to the grant will review interest income earned throughout the fiscal year and ensure any amount exceeding $500 is returned to the Department of Health and Human Services.
2023 002 Assistance Listing, Federal Agency, and Program Name ALN 10.557, U.S. Department of Agriculture, Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) Federal Award Identification Number and Year E20233413 00 (2023) and E20232456 00 (2023) Pass through Entity Michigan Department of Health and Human Services Finding Type Significant deficiency Repeat Finding No Criteria Per 2 CFR section 200.305(b)(9), interest earned amounts up to $500 per year may be retained by the non Federal entity for administrative expense. Any additional interest earned on Federal advanced payments deposited in interest bearing accounts must be remitted annually to the Department of Health and Human Services Payment Management System (PMS)t. Condition The County did not track WIC interest income earned throughout the fiscal year, resulting in the County not refunding the Department of Health and Human Services the excess of $500 earned during the year. Questioned Costs $806 Identification of How Questioned Costs Were Computed The County determined that there was $1,306 of interest earned, less $500 that can be retained for administrative expense, results in $806 that should have been remitted back to the Department of Health and Human Services. Context From October 1, 2022 through September 30, 2023, the County received advanced payments for the WIC program, which were held in an interest bearing account and those funds earned interest in excess of $500. Cause and Effect The County did not have a control in place to track the interest earned on WIC advanced payments to note if they exceeded $500 throughout the year. This resulted in the County not properly remitting the excess interest amount earned back to the Department of Health and Human Services at the end of the fiscal year. Recommendation We recommend that an internal control be put in place to monitor interest earned monthly or quarterly, to ensure that if it exceeds $500 on WIC advance payments, that it is properly remitted back to the Department of Health and Human Resources annually. Views of Responsible Officials and Planned Corrective Actions The financial analyst assigned to the grant will review interest income earned throughout the fiscal year and ensure any amount exceeding $500 is returned to the Department of Health and Human Services.
Finding 2023-003 – Cash Collateralization Criteria: Uniform Guidance 2 CFR, Part §200.305(b)(7) requires advance payments of Federal funds to be deposited and maintained in insured accounts whenever possible. Condition: During our review of the Coalition’s cash, it was noted that as of September 30, 2023, they have not collateralized cash balances in excess of the amounts insured by the Federal Despot Insurance Corporation. Cash balances of $10,608,222 were uninsured at September 30, 2023. Unearned revenue was reported at approximately $5,389,532 which includes advance payments of Federal funds. Questioned Costs: None Cause: The Coalition has not entered into a cash collateralization agreement with their financial institution. Effect: The Coalition is not in compliance with Uniform Guidance 2 CFR, Part §200.305(b)(7) as not all cash balances received in advance from the funding agency were adequately insured or collateralized and were exposed to custodial credit risk in the event of a bank failure. Recommendation: We recommend the Coalition enter into a cash collateralization agreement with their financial institution to ensure that all amounts related to grant agreements and awards received in advance are not exposed to custodial credit risk in the event of a bank failure. Views of Responsible Officials: See the corrective action plan that accompanies the schedule of findings and questioned costs.
Finding 2023-003 – Cash Collateralization Criteria: Uniform Guidance 2 CFR, Part §200.305(b)(7) requires advance payments of Federal funds to be deposited and maintained in insured accounts whenever possible. Condition: During our review of the Coalition’s cash, it was noted that as of September 30, 2023, they have not collateralized cash balances in excess of the amounts insured by the Federal Despot Insurance Corporation. Cash balances of $10,608,222 were uninsured at September 30, 2023. Unearned revenue was reported at approximately $5,389,532 which includes advance payments of Federal funds. Questioned Costs: None Cause: The Coalition has not entered into a cash collateralization agreement with their financial institution. Effect: The Coalition is not in compliance with Uniform Guidance 2 CFR, Part §200.305(b)(7) as not all cash balances received in advance from the funding agency were adequately insured or collateralized and were exposed to custodial credit risk in the event of a bank failure. Recommendation: We recommend the Coalition enter into a cash collateralization agreement with their financial institution to ensure that all amounts related to grant agreements and awards received in advance are not exposed to custodial credit risk in the event of a bank failure. Views of Responsible Officials: See the corrective action plan that accompanies the schedule of findings and questioned costs.
Finding: 2023-002-Nonmaterial Noncompliance – Timing between the transfer of funds and disbursement of costs Federal Program: 93.XXX U.S. Department of Health and Human Services Condition: The Institute was not able to provide us detailed support showing that time elapsing between the receipt of funds from the federal agency or pass-through entity and disbursement of funds for direct program or project costs and the proportionate share of allowable indirect costs was minimized. Criteria: In accordance with the Compliance Supplement, non-federal entities must minimize the time elapsing between the transfer of funds from the U.S. Treasury or pass-through entity and disbursement by the non-federal entity for direct program or project costs and the proportionate share of allowable indirect costs, whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means (2 CFR Section 200.305(b)). Under the advance payment method, federal awarding agency or pass-through entity payment is made to the non-federal entity before the non-federal entity disburses the funds for program purposes (2 CFR Section 200.1). A non-federal entity must be paid in advance provided that it maintains, or demonstrates the willingness to maintain, both written procedures that minimize the time elapsing between the transfer of funds from the U.S. Treasury and disbursement by the non-federal entity, as well as a financial management system that meets the specified standards for fund control and accountability (2 CFR Section 200.305(b)(1)). Cause: The Institute received funds in accordance with fixed price payment schedules and did not maintain documentation of the time elapsing between the receipt and disbursement of such funds. Effect: The Institute may have earned interest on federal funds during the time elapsed between receipt and disbursement of federal funds. Questioned Costs: None noted. Repeat Finding: No. Recommendation: We recommend the Institute establish an internal control in which an individual review the time elapsing between receipt and disbursement of federal funds. Corrective Action Plan: The Institute implemented the recommendations in the fourth quarter of fiscal year 2024.
Finding: 2023-002-Nonmaterial Noncompliance – Timing between the transfer of funds and disbursement of costs Federal Program: 93.XXX U.S. Department of Health and Human Services Condition: The Institute was not able to provide us detailed support showing that time elapsing between the receipt of funds from the federal agency or pass-through entity and disbursement of funds for direct program or project costs and the proportionate share of allowable indirect costs was minimized. Criteria: In accordance with the Compliance Supplement, non-federal entities must minimize the time elapsing between the transfer of funds from the U.S. Treasury or pass-through entity and disbursement by the non-federal entity for direct program or project costs and the proportionate share of allowable indirect costs, whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means (2 CFR Section 200.305(b)). Under the advance payment method, federal awarding agency or pass-through entity payment is made to the non-federal entity before the non-federal entity disburses the funds for program purposes (2 CFR Section 200.1). A non-federal entity must be paid in advance provided that it maintains, or demonstrates the willingness to maintain, both written procedures that minimize the time elapsing between the transfer of funds from the U.S. Treasury and disbursement by the non-federal entity, as well as a financial management system that meets the specified standards for fund control and accountability (2 CFR Section 200.305(b)(1)). Cause: The Institute received funds in accordance with fixed price payment schedules and did not maintain documentation of the time elapsing between the receipt and disbursement of such funds. Effect: The Institute may have earned interest on federal funds during the time elapsed between receipt and disbursement of federal funds. Questioned Costs: None noted. Repeat Finding: No. Recommendation: We recommend the Institute establish an internal control in which an individual review the time elapsing between receipt and disbursement of federal funds. Corrective Action Plan: The Institute implemented the recommendations in the fourth quarter of fiscal year 2024.
Finding: 2023-002-Nonmaterial Noncompliance – Timing between the transfer of funds and disbursement of costs Federal Program: 93.XXX U.S. Department of Health and Human Services Condition: The Institute was not able to provide us detailed support showing that time elapsing between the receipt of funds from the federal agency or pass-through entity and disbursement of funds for direct program or project costs and the proportionate share of allowable indirect costs was minimized. Criteria: In accordance with the Compliance Supplement, non-federal entities must minimize the time elapsing between the transfer of funds from the U.S. Treasury or pass-through entity and disbursement by the non-federal entity for direct program or project costs and the proportionate share of allowable indirect costs, whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means (2 CFR Section 200.305(b)). Under the advance payment method, federal awarding agency or pass-through entity payment is made to the non-federal entity before the non-federal entity disburses the funds for program purposes (2 CFR Section 200.1). A non-federal entity must be paid in advance provided that it maintains, or demonstrates the willingness to maintain, both written procedures that minimize the time elapsing between the transfer of funds from the U.S. Treasury and disbursement by the non-federal entity, as well as a financial management system that meets the specified standards for fund control and accountability (2 CFR Section 200.305(b)(1)). Cause: The Institute received funds in accordance with fixed price payment schedules and did not maintain documentation of the time elapsing between the receipt and disbursement of such funds. Effect: The Institute may have earned interest on federal funds during the time elapsed between receipt and disbursement of federal funds. Questioned Costs: None noted. Repeat Finding: No. Recommendation: We recommend the Institute establish an internal control in which an individual review the time elapsing between receipt and disbursement of federal funds. Corrective Action Plan: The Institute implemented the recommendations in the fourth quarter of fiscal year 2024.
Finding: 2023-002-Nonmaterial Noncompliance – Timing between the transfer of funds and disbursement of costs Federal Program: 93.XXX U.S. Department of Health and Human Services Condition: The Institute was not able to provide us detailed support showing that time elapsing between the receipt of funds from the federal agency or pass-through entity and disbursement of funds for direct program or project costs and the proportionate share of allowable indirect costs was minimized. Criteria: In accordance with the Compliance Supplement, non-federal entities must minimize the time elapsing between the transfer of funds from the U.S. Treasury or pass-through entity and disbursement by the non-federal entity for direct program or project costs and the proportionate share of allowable indirect costs, whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means (2 CFR Section 200.305(b)). Under the advance payment method, federal awarding agency or pass-through entity payment is made to the non-federal entity before the non-federal entity disburses the funds for program purposes (2 CFR Section 200.1). A non-federal entity must be paid in advance provided that it maintains, or demonstrates the willingness to maintain, both written procedures that minimize the time elapsing between the transfer of funds from the U.S. Treasury and disbursement by the non-federal entity, as well as a financial management system that meets the specified standards for fund control and accountability (2 CFR Section 200.305(b)(1)). Cause: The Institute received funds in accordance with fixed price payment schedules and did not maintain documentation of the time elapsing between the receipt and disbursement of such funds. Effect: The Institute may have earned interest on federal funds during the time elapsed between receipt and disbursement of federal funds. Questioned Costs: None noted. Repeat Finding: No. Recommendation: We recommend the Institute establish an internal control in which an individual review the time elapsing between receipt and disbursement of federal funds. Corrective Action Plan: The Institute implemented the recommendations in the fourth quarter of fiscal year 2024.
Finding: 2023-002-Nonmaterial Noncompliance – Timing between the transfer of funds and disbursement of costs Federal Program: 93.XXX U.S. Department of Health and Human Services Condition: The Institute was not able to provide us detailed support showing that time elapsing between the receipt of funds from the federal agency or pass-through entity and disbursement of funds for direct program or project costs and the proportionate share of allowable indirect costs was minimized. Criteria: In accordance with the Compliance Supplement, non-federal entities must minimize the time elapsing between the transfer of funds from the U.S. Treasury or pass-through entity and disbursement by the non-federal entity for direct program or project costs and the proportionate share of allowable indirect costs, whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means (2 CFR Section 200.305(b)). Under the advance payment method, federal awarding agency or pass-through entity payment is made to the non-federal entity before the non-federal entity disburses the funds for program purposes (2 CFR Section 200.1). A non-federal entity must be paid in advance provided that it maintains, or demonstrates the willingness to maintain, both written procedures that minimize the time elapsing between the transfer of funds from the U.S. Treasury and disbursement by the non-federal entity, as well as a financial management system that meets the specified standards for fund control and accountability (2 CFR Section 200.305(b)(1)). Cause: The Institute received funds in accordance with fixed price payment schedules and did not maintain documentation of the time elapsing between the receipt and disbursement of such funds. Effect: The Institute may have earned interest on federal funds during the time elapsed between receipt and disbursement of federal funds. Questioned Costs: None noted. Repeat Finding: No. Recommendation: We recommend the Institute establish an internal control in which an individual review the time elapsing between receipt and disbursement of federal funds. Corrective Action Plan: The Institute implemented the recommendations in the fourth quarter of fiscal year 2024.
Finding: 2023-002-Nonmaterial Noncompliance – Timing between the transfer of funds and disbursement of costs Federal Program: 93.XXX U.S. Department of Health and Human Services Condition: The Institute was not able to provide us detailed support showing that time elapsing between the receipt of funds from the federal agency or pass-through entity and disbursement of funds for direct program or project costs and the proportionate share of allowable indirect costs was minimized. Criteria: In accordance with the Compliance Supplement, non-federal entities must minimize the time elapsing between the transfer of funds from the U.S. Treasury or pass-through entity and disbursement by the non-federal entity for direct program or project costs and the proportionate share of allowable indirect costs, whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means (2 CFR Section 200.305(b)). Under the advance payment method, federal awarding agency or pass-through entity payment is made to the non-federal entity before the non-federal entity disburses the funds for program purposes (2 CFR Section 200.1). A non-federal entity must be paid in advance provided that it maintains, or demonstrates the willingness to maintain, both written procedures that minimize the time elapsing between the transfer of funds from the U.S. Treasury and disbursement by the non-federal entity, as well as a financial management system that meets the specified standards for fund control and accountability (2 CFR Section 200.305(b)(1)). Cause: The Institute received funds in accordance with fixed price payment schedules and did not maintain documentation of the time elapsing between the receipt and disbursement of such funds. Effect: The Institute may have earned interest on federal funds during the time elapsed between receipt and disbursement of federal funds. Questioned Costs: None noted. Repeat Finding: No. Recommendation: We recommend the Institute establish an internal control in which an individual review the time elapsing between receipt and disbursement of federal funds. Corrective Action Plan: The Institute implemented the recommendations in the fourth quarter of fiscal year 2024.
Finding: 2023-002-Nonmaterial Noncompliance – Timing between the transfer of funds and disbursement of costs Federal Program: 93.XXX U.S. Department of Health and Human Services Condition: The Institute was not able to provide us detailed support showing that time elapsing between the receipt of funds from the federal agency or pass-through entity and disbursement of funds for direct program or project costs and the proportionate share of allowable indirect costs was minimized. Criteria: In accordance with the Compliance Supplement, non-federal entities must minimize the time elapsing between the transfer of funds from the U.S. Treasury or pass-through entity and disbursement by the non-federal entity for direct program or project costs and the proportionate share of allowable indirect costs, whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means (2 CFR Section 200.305(b)). Under the advance payment method, federal awarding agency or pass-through entity payment is made to the non-federal entity before the non-federal entity disburses the funds for program purposes (2 CFR Section 200.1). A non-federal entity must be paid in advance provided that it maintains, or demonstrates the willingness to maintain, both written procedures that minimize the time elapsing between the transfer of funds from the U.S. Treasury and disbursement by the non-federal entity, as well as a financial management system that meets the specified standards for fund control and accountability (2 CFR Section 200.305(b)(1)). Cause: The Institute received funds in accordance with fixed price payment schedules and did not maintain documentation of the time elapsing between the receipt and disbursement of such funds. Effect: The Institute may have earned interest on federal funds during the time elapsed between receipt and disbursement of federal funds. Questioned Costs: None noted. Repeat Finding: No. Recommendation: We recommend the Institute establish an internal control in which an individual review the time elapsing between receipt and disbursement of federal funds. Corrective Action Plan: The Institute implemented the recommendations in the fourth quarter of fiscal year 2024.
2023-001 CASH MANAGEMENT U.S. Department of Environmental Protection ALN 66.456 – National Estuary Program Federal Award ID Number: 4T-02D39922 2023 Funding Criteria: 2 CFR 200.303 requires non-federal entities to establish and maintain effective internal controls. As required by 2 CFR 200.305(b), grant recipients may only draw funds for the minimum amounts needed for actual and immediate cash requirements to pay employees, contractors, subrecipients or to satisfy other obligations for allowable costs under the grant agreement. Disbursements within five (5) business days of the drawdown are deemed to comply with this requirement. Condition: On December 19, 2022 the grantee drew down their entire award of $909,800, but only $300,000 was for reimbursable expenses. The remaining $609,800 was an advance which is not permitted under the award terms or Uniform Guidance. The erroneous advance was identified by the grantor and returned by the Council on December 29, 2022. Cause: Council management misunderstood the award terms and the allowability of advances. Effect: Draws of funds in excess of amounts needed for actual and immediate cash requirements can result in the return of funds. Questioned Costs: None. Perspective: During our testing, we did not note any other instances in which funds were drawn on an advance basis, in excess of costs already incurred by the Council. The Council misunderstood guidance from the grantor, which led to the draw down of funds in advance of current needs. Recommendation: Management should obtain clarification in writing from the grantor on guidance outside of the established procedures to prevent future misunderstandings.
DEPARTMENT OF HEALTH AND HUMAN SERVICES 2023-002 Immunization Cooperative Agreements, ALN #93.268 Criteria: According to 2 CFR Section 200.305(b)(3), all reimbursement requests should be based on supporting documentation that shows the cost was incurred before the request for payment and that the payment to vendor was made. Condition: 4 of the 7 cash drawdown reports tested contained expense reimbursements requested for which there was missing supporting documentation for some of the expenses requested for reimbursements. Total questioned costs were $115,617. Cause: The extra expenses that were missing in the test were because IAFP used staff instead of consultants and the Organization did not update our policies and procedures to include time sheets to show how staff was allocated to the grant to support the charges. Effect: The effect is that the Organization requested funds but did not have back up to support that the actual expenses were incurred and was therefore not in compliance with the cash management requirements under Uniform Grant Guidance in relation reimbursement requests. Auditor recommendation: We recommend that the accounting department verify that the expense has been incurred and paid to the vendor before requesting reimbursement from the grantor and ensure that the backup documentation is filed where it can be located. We recommend hiring or training staff in relation to cash management and documentation of allowable cost. Management response: Management will follow the advice and undergo training in cash management and documentation of allowable costs.
Condition: Although the City drewdown and received approximately $2.5M in grant funds, it had expended only approximately $1.49M for the fiscal year ended September 30, 2023. Criteria: Non-federal entities must minimize the time elapsing between the transfer of funds from the U.S. Treasury or pass-through entity and disbursement by the non-federal entity for direct program or project costs and the proportionate share of allowable indirect costs whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means (2 CFR section 200.305(b), 45 CFR Part 75.305(b)). According to the Office of Management and Budget 2023 Compliance Supplement, what constitutes minimized elapsed time for funds transfer depends on the method of payment the auditee uses. The U.S. Department of Health and Human Services (HHS) processes its financial transaction through its Program Support Center, which uses the Payment Management System (PMS). Payments requested through the HHS PMS are generally available to the auditee the next business day. Under the advance payment method, payment may be made to the auditee prior to the auditee's disbursement of program funds, so long as the auditee "...maintains, or demonstrates the willingness to maintain, both written procedures that minimize the time elapsing between the transfer of funds from the U.S. Treasury and disbursement by the non-federal entity..." Cause: The City requested and received grant funds prior to having a need for such funds. Effect: The City did not comply with cash management requirements as set forth by the Office of Management and Budget (OMB), 2 CFR section 200.305(b), and 45 CFR Part 75.305(b). As a result, at the end of the fiscal year, the City had in more than $1M in HHS funds in its financial institution account. Questioned costs: N/A Recommendation: We recommend that the City develop and implement procedures to ensure that federal funds are only either requested as reimbursement for allowable program disbursement. In those instances where a federal program allow advance payments, procedures should be implemented to ensure that those payments are for immediate cash needs City's Response: The City will not draw down any grant funds prior to incurring the expenditure.
2023-005: Written Policies and Procedures Assistance Listing Number, Federal Agency, and Program Name: Assistance Listing Number 93.696, Certified Community Behavioral Health Clinic Expansion Grant Federal Award Identification Number and Year: 1H79SM086680-01, Program Grant Period 09/29/2022-09/29/2023 Pass-through Entity: N/A Type: Material weakness in internal control and noncompliance with laws and regulations Repeat Finding: No Criteria: As a precondition to receive federal awards, prospective recipients must have effective internal controls over the federal award. As described in 2 CFR, Part 200.303, nonfederal entities must have certain written policies and procedures surrounding the management of their federal awards. Such policies should include procedures for collecting payments of federal funds per 2 CRF 200.305, cash management (i.e., minimizing the time between draws and actual disbursing of federal awards) per 2 CFR 200.302(b)(6), allowable cost per 2 CFR 200.403, and conflict of interest per 2 CFR 200.318. Per 2 CFR 200.319(d), the non-Federal entity must have written procedures for procurement transactions. Condition: The Authority did not have written procedures for cash management and allowable cost. Identification of How Likely Questioned Costs Were Computed: N/A Known Questioned Costs: None Context: N/A Cause/Effect: Although the Authority is aware that they were required to have written policies and procedures for the items noted above, they were using the grant agreement guidelines that provide grantees with guidance for ensuring the existing accounting and personnel policies and procedures include the necessary controls. These guidelines address the compliance areas required by the Uniform Guidance. Recommendation: We recommend the Authority adopt written policies and procedures over cash management and allowable costs required under the Uniform Guidance. View of Responsible Officials and Planned Corrective Action Plan: See attached corrective action plan.
AL Numbers: 93.568 Name of Federal Program or Cluster: Low-Income Home Energy Assistance Program (LIHEAP) and COVID-19 LIHEAP Award Number: 23PANDLIEA, 23PANDLIEE, 23 PANDLIEI Award Year: 2023 Criteria – In accordance with the Tribe’s grant award requirements and the Uniform Guidance 2 CFR 200.305, the timing and amount of advance payments must be as close as is administratively feasible to the actual disbursements for project costs. Condition and context – The LIHEAP program had a significant amount of unearned revenue (i.e., unspent advanced grant funds) as of September 30, 2023, which was not expended within a reasonable amount of time. Cause – Lack of sufficient oversight on cash management requirements may have led to this finding. Questioned costs – There are no questioned costs to report related to this finding as the advanced funds were unexpended. Effect – Failure to adhere to these requirements can potentially cause the suspension of grant funds. Repeat finding – This is a repeat finding and was reported in the prior year as finding 2022-010. Recommendation – LIHEAP program should implement a supervisory review process over the cash management and drawdown process to ensure compliance with the requirements. Views of responsible officials and planned corrective actions – The Program will work with the finance department to better match advanced drawdowns to the actual disbursement for the period. This will be done by comparing the funds on hand (bank balance) to program costs. If sufficient funds are on hand a drawdown request will not be made.
AL Numbers: 93.568 Name of Federal Program or Cluster: Low-Income Home Energy Assistance Program (LIHEAP) and COVID-19 LIHEAP Award Number: 23PANDLIEA, 23PANDLIEE, 23 PANDLIEI Award Year: 2023 Criteria – In accordance with the Tribe’s grant award requirements and the Uniform Guidance 2 CFR 200.305, the timing and amount of advance payments must be as close as is administratively feasible to the actual disbursements for project costs. Condition and context – The LIHEAP program had a significant amount of unearned revenue (i.e., unspent advanced grant funds) as of September 30, 2023, which was not expended within a reasonable amount of time. Cause – Lack of sufficient oversight on cash management requirements may have led to this finding. Questioned costs – There are no questioned costs to report related to this finding as the advanced funds were unexpended. Effect – Failure to adhere to these requirements can potentially cause the suspension of grant funds. Repeat finding – This is a repeat finding and was reported in the prior year as finding 2022-010. Recommendation – LIHEAP program should implement a supervisory review process over the cash management and drawdown process to ensure compliance with the requirements. Views of responsible officials and planned corrective actions – The Program will work with the finance department to better match advanced drawdowns to the actual disbursement for the period. This will be done by comparing the funds on hand (bank balance) to program costs. If sufficient funds are on hand a drawdown request will not be made.
U.S. Department of Justice Crime Victim Assistance – Assistance #16.575 #2023-009 – Major Federal Award Finding – Cash Management Nature of Finding: Compliance Finding Cash Management and Significant Deficiency in Internal Controls over Compliance Criteria/Condition: 2 CFR 200.305 requires that non-federal entities must minimize the time elapsing between the transfer of federal funds to the non-federal entity and the subsequent disbursement of the funds by the non-federal entity for program costs. The Organization did not have proper controls in place to verify that specific vendor invoices were paid within a reasonable amount of time of requesting reimbursement for the expenditures. Questioned Costs: $2,381 Identification of How Questioned Costs Were Computed: The issues of noncompliance related to cash management was limited to one vendor that was not paid within a reasonable amount of time of being reimbursed for the costs. This was determined to be an isolated incident. Questioned costs include the two invoices that were charged to the grant for this vendor during the year ended September 30, 2023 and were not paid to the vendor within a reasonable amount of time of being reimbursed for the expenditures. Cause/Context: Controls were not in place to ensure expenditures were paid to the vendor prior to requesting reimbursements. This circumstance was determined to be an isolated incident due to the unique nature of the vendor invoices. The Organization was withholding payment to the vendor until it determined that both invoices were proper. Effect: The lack of controls could result in requests for reimbursement being submitted for unpaid expenditures. Recommendation: We recommend the Organization establish procedures and incorporate controls to review that expenditures are paid prior to submitting requests for reimbursement. Views of Responsible Officials and Planned Corrective Actions: The Organization will implement the following changes in its accounting procedures: Each month, an aged open accounts payable report will be produced as part of the month end closing. Invoices that are past due will be paid in the following batch of payments (which are typically run weekly). If it is determined that the invoice is not being paid for a valid reason, it will be removed from accounts payable at that time.
U.S. Department of Justice Crime Victim Assistance – Assistance #16.575 #2023-009 – Major Federal Award Finding – Cash Management Nature of Finding: Compliance Finding Cash Management and Significant Deficiency in Internal Controls over Compliance Criteria/Condition: 2 CFR 200.305 requires that non-federal entities must minimize the time elapsing between the transfer of federal funds to the non-federal entity and the subsequent disbursement of the funds by the non-federal entity for program costs. The Organization did not have proper controls in place to verify that specific vendor invoices were paid within a reasonable amount of time of requesting reimbursement for the expenditures. Questioned Costs: $2,381 Identification of How Questioned Costs Were Computed: The issues of noncompliance related to cash management was limited to one vendor that was not paid within a reasonable amount of time of being reimbursed for the costs. This was determined to be an isolated incident. Questioned costs include the two invoices that were charged to the grant for this vendor during the year ended September 30, 2023 and were not paid to the vendor within a reasonable amount of time of being reimbursed for the expenditures. Cause/Context: Controls were not in place to ensure expenditures were paid to the vendor prior to requesting reimbursements. This circumstance was determined to be an isolated incident due to the unique nature of the vendor invoices. The Organization was withholding payment to the vendor until it determined that both invoices were proper. Effect: The lack of controls could result in requests for reimbursement being submitted for unpaid expenditures. Recommendation: We recommend the Organization establish procedures and incorporate controls to review that expenditures are paid prior to submitting requests for reimbursement. Views of Responsible Officials and Planned Corrective Actions: The Organization will implement the following changes in its accounting procedures: Each month, an aged open accounts payable report will be produced as part of the month end closing. Invoices that are past due will be paid in the following batch of payments (which are typically run weekly). If it is determined that the invoice is not being paid for a valid reason, it will be removed from accounts payable at that time. #2023-010 – Major Federal Award Finding – Period of Performance Nature of Finding: Compliance Finding Period of Performance and Material Weakness in Internal Controls over Compliance Criteria/Condition: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance. The Organization did not have controls in place to verify that costs were being charged to the award in the correct period of performance. Questioned Costs: $20,790 Identification of How Questioned Costs Were Computed: A sample of 40 non-payroll expenditures totaling approximately $48,000 was selected from a population of approximately $552,000 of non-payroll expenditures. An amount of $1,817 combined from two invoices that were charged to the Crime Victim Assistance program was related to the year ending September 30, 2024 and was inappropriately charged to the grant during 2023. Questioned costs are estimated by projecting the error identified in the sample tested to the population of non-payroll expenditures of the Crime Victim Assistance program. Cause/Context: There are not proper controls in place to review invoices and assign them to the appropriate grant period. Two expenditures out of forty non-payroll related expenditures tested for the Crime Victim Assistance grant was for a contracted annual service that covered multiple performance periods but was billed in its entirety to the current fiscal year. Effect: An overstatement of expenditures for the Crime Victim Assistance grant was reported in the current year. Recommendation: We recommend procedures are established to review for proper grant period when recording transactions and creating monthly reimbursement requests. Views of Responsible Officials and Planned Corrective Actions: The Organization will implement the following changes in its accounting procedures. 1. The Staff Accountant will review the period each expenditure is related to and record the invoice to the appropriate period when entering it into accounts payable. The month and year will be noted on the invoice. 2. The CFO will review the month and year noted by the Staff Accountant prior to entry into accounts payable.
U.S. Department of Justice Crime Victim Assistance – Assistance #16.575 #2023-009 – Major Federal Award Finding – Cash Management Nature of Finding: Compliance Finding Cash Management and Significant Deficiency in Internal Controls over Compliance Criteria/Condition: 2 CFR 200.305 requires that non-federal entities must minimize the time elapsing between the transfer of federal funds to the non-federal entity and the subsequent disbursement of the funds by the non-federal entity for program costs. The Organization did not have proper controls in place to verify that specific vendor invoices were paid within a reasonable amount of time of requesting reimbursement for the expenditures. Questioned Costs: $2,381 Identification of How Questioned Costs Were Computed: The issues of noncompliance related to cash management was limited to one vendor that was not paid within a reasonable amount of time of being reimbursed for the costs. This was determined to be an isolated incident. Questioned costs include the two invoices that were charged to the grant for this vendor during the year ended September 30, 2023 and were not paid to the vendor within a reasonable amount of time of being reimbursed for the expenditures. Cause/Context: Controls were not in place to ensure expenditures were paid to the vendor prior to requesting reimbursements. This circumstance was determined to be an isolated incident due to the unique nature of the vendor invoices. The Organization was withholding payment to the vendor until it determined that both invoices were proper. Effect: The lack of controls could result in requests for reimbursement being submitted for unpaid expenditures. Recommendation: We recommend the Organization establish procedures and incorporate controls to review that expenditures are paid prior to submitting requests for reimbursement. Views of Responsible Officials and Planned Corrective Actions: The Organization will implement the following changes in its accounting procedures: Each month, an aged open accounts payable report will be produced as part of the month end closing. Invoices that are past due will be paid in the following batch of payments (which are typically run weekly). If it is determined that the invoice is not being paid for a valid reason, it will be removed from accounts payable at that time.
U.S. Department of Justice Crime Victim Assistance – Assistance #16.575 #2023-009 – Major Federal Award Finding – Cash Management Nature of Finding: Compliance Finding Cash Management and Significant Deficiency in Internal Controls over Compliance Criteria/Condition: 2 CFR 200.305 requires that non-federal entities must minimize the time elapsing between the transfer of federal funds to the non-federal entity and the subsequent disbursement of the funds by the non-federal entity for program costs. The Organization did not have proper controls in place to verify that specific vendor invoices were paid within a reasonable amount of time of requesting reimbursement for the expenditures. Questioned Costs: $2,381 Identification of How Questioned Costs Were Computed: The issues of noncompliance related to cash management was limited to one vendor that was not paid within a reasonable amount of time of being reimbursed for the costs. This was determined to be an isolated incident. Questioned costs include the two invoices that were charged to the grant for this vendor during the year ended September 30, 2023 and were not paid to the vendor within a reasonable amount of time of being reimbursed for the expenditures. Cause/Context: Controls were not in place to ensure expenditures were paid to the vendor prior to requesting reimbursements. This circumstance was determined to be an isolated incident due to the unique nature of the vendor invoices. The Organization was withholding payment to the vendor until it determined that both invoices were proper. Effect: The lack of controls could result in requests for reimbursement being submitted for unpaid expenditures. Recommendation: We recommend the Organization establish procedures and incorporate controls to review that expenditures are paid prior to submitting requests for reimbursement. Views of Responsible Officials and Planned Corrective Actions: The Organization will implement the following changes in its accounting procedures: Each month, an aged open accounts payable report will be produced as part of the month end closing. Invoices that are past due will be paid in the following batch of payments (which are typically run weekly). If it is determined that the invoice is not being paid for a valid reason, it will be removed from accounts payable at that time. #2023-010 – Major Federal Award Finding – Period of Performance Nature of Finding: Compliance Finding Period of Performance and Material Weakness in Internal Controls over Compliance Criteria/Condition: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance. The Organization did not have controls in place to verify that costs were being charged to the award in the correct period of performance. Questioned Costs: $20,790 Identification of How Questioned Costs Were Computed: A sample of 40 non-payroll expenditures totaling approximately $48,000 was selected from a population of approximately $552,000 of non-payroll expenditures. An amount of $1,817 combined from two invoices that were charged to the Crime Victim Assistance program was related to the year ending September 30, 2024 and was inappropriately charged to the grant during 2023. Questioned costs are estimated by projecting the error identified in the sample tested to the population of non-payroll expenditures of the Crime Victim Assistance program. Cause/Context: There are not proper controls in place to review invoices and assign them to the appropriate grant period. Two expenditures out of forty non-payroll related expenditures tested for the Crime Victim Assistance grant was for a contracted annual service that covered multiple performance periods but was billed in its entirety to the current fiscal year. Effect: An overstatement of expenditures for the Crime Victim Assistance grant was reported in the current year. Recommendation: We recommend procedures are established to review for proper grant period when recording transactions and creating monthly reimbursement requests. Views of Responsible Officials and Planned Corrective Actions: The Organization will implement the following changes in its accounting procedures. 1. The Staff Accountant will review the period each expenditure is related to and record the invoice to the appropriate period when entering it into accounts payable. The month and year will be noted on the invoice. 2. The CFO will review the month and year noted by the Staff Accountant prior to entry into accounts payable.
U.S. Department of Justice Crime Victim Assistance – Assistance #16.575 #2023-009 – Major Federal Award Finding – Cash Management Nature of Finding: Compliance Finding Cash Management and Significant Deficiency in Internal Controls over Compliance Criteria/Condition: 2 CFR 200.305 requires that non-federal entities must minimize the time elapsing between the transfer of federal funds to the non-federal entity and the subsequent disbursement of the funds by the non-federal entity for program costs. The Organization did not have proper controls in place to verify that specific vendor invoices were paid within a reasonable amount of time of requesting reimbursement for the expenditures. Questioned Costs: $2,381 Identification of How Questioned Costs Were Computed: The issues of noncompliance related to cash management was limited to one vendor that was not paid within a reasonable amount of time of being reimbursed for the costs. This was determined to be an isolated incident. Questioned costs include the two invoices that were charged to the grant for this vendor during the year ended September 30, 2023 and were not paid to the vendor within a reasonable amount of time of being reimbursed for the expenditures. Cause/Context: Controls were not in place to ensure expenditures were paid to the vendor prior to requesting reimbursements. This circumstance was determined to be an isolated incident due to the unique nature of the vendor invoices. The Organization was withholding payment to the vendor until it determined that both invoices were proper. Effect: The lack of controls could result in requests for reimbursement being submitted for unpaid expenditures. Recommendation: We recommend the Organization establish procedures and incorporate controls to review that expenditures are paid prior to submitting requests for reimbursement. Views of Responsible Officials and Planned Corrective Actions: The Organization will implement the following changes in its accounting procedures: Each month, an aged open accounts payable report will be produced as part of the month end closing. Invoices that are past due will be paid in the following batch of payments (which are typically run weekly). If it is determined that the invoice is not being paid for a valid reason, it will be removed from accounts payable at that time.
U.S. Department of Justice Crime Victim Assistance – Assistance #16.575 #2023-009 – Major Federal Award Finding – Cash Management Nature of Finding: Compliance Finding Cash Management and Significant Deficiency in Internal Controls over Compliance Criteria/Condition: 2 CFR 200.305 requires that non-federal entities must minimize the time elapsing between the transfer of federal funds to the non-federal entity and the subsequent disbursement of the funds by the non-federal entity for program costs. The Organization did not have proper controls in place to verify that specific vendor invoices were paid within a reasonable amount of time of requesting reimbursement for the expenditures. Questioned Costs: $2,381 Identification of How Questioned Costs Were Computed: The issues of noncompliance related to cash management was limited to one vendor that was not paid within a reasonable amount of time of being reimbursed for the costs. This was determined to be an isolated incident. Questioned costs include the two invoices that were charged to the grant for this vendor during the year ended September 30, 2023 and were not paid to the vendor within a reasonable amount of time of being reimbursed for the expenditures. Cause/Context: Controls were not in place to ensure expenditures were paid to the vendor prior to requesting reimbursements. This circumstance was determined to be an isolated incident due to the unique nature of the vendor invoices. The Organization was withholding payment to the vendor until it determined that both invoices were proper. Effect: The lack of controls could result in requests for reimbursement being submitted for unpaid expenditures. Recommendation: We recommend the Organization establish procedures and incorporate controls to review that expenditures are paid prior to submitting requests for reimbursement. Views of Responsible Officials and Planned Corrective Actions: The Organization will implement the following changes in its accounting procedures: Each month, an aged open accounts payable report will be produced as part of the month end closing. Invoices that are past due will be paid in the following batch of payments (which are typically run weekly). If it is determined that the invoice is not being paid for a valid reason, it will be removed from accounts payable at that time. #2023-010 – Major Federal Award Finding – Period of Performance Nature of Finding: Compliance Finding Period of Performance and Material Weakness in Internal Controls over Compliance Criteria/Condition: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance. The Organization did not have controls in place to verify that costs were being charged to the award in the correct period of performance. Questioned Costs: $20,790 Identification of How Questioned Costs Were Computed: A sample of 40 non-payroll expenditures totaling approximately $48,000 was selected from a population of approximately $552,000 of non-payroll expenditures. An amount of $1,817 combined from two invoices that were charged to the Crime Victim Assistance program was related to the year ending September 30, 2024 and was inappropriately charged to the grant during 2023. Questioned costs are estimated by projecting the error identified in the sample tested to the population of non-payroll expenditures of the Crime Victim Assistance program. Cause/Context: There are not proper controls in place to review invoices and assign them to the appropriate grant period. Two expenditures out of forty non-payroll related expenditures tested for the Crime Victim Assistance grant was for a contracted annual service that covered multiple performance periods but was billed in its entirety to the current fiscal year. Effect: An overstatement of expenditures for the Crime Victim Assistance grant was reported in the current year. Recommendation: We recommend procedures are established to review for proper grant period when recording transactions and creating monthly reimbursement requests. Views of Responsible Officials and Planned Corrective Actions: The Organization will implement the following changes in its accounting procedures. 1. The Staff Accountant will review the period each expenditure is related to and record the invoice to the appropriate period when entering it into accounts payable. The month and year will be noted on the invoice. 2. The CFO will review the month and year noted by the Staff Accountant prior to entry into accounts payable.
U.S. Department of Justice Crime Victim Assistance – Assistance #16.575 #2023-009 – Major Federal Award Finding – Cash Management Nature of Finding: Compliance Finding Cash Management and Significant Deficiency in Internal Controls over Compliance Criteria/Condition: 2 CFR 200.305 requires that non-federal entities must minimize the time elapsing between the transfer of federal funds to the non-federal entity and the subsequent disbursement of the funds by the non-federal entity for program costs. The Organization did not have proper controls in place to verify that specific vendor invoices were paid within a reasonable amount of time of requesting reimbursement for the expenditures. Questioned Costs: $2,381 Identification of How Questioned Costs Were Computed: The issues of noncompliance related to cash management was limited to one vendor that was not paid within a reasonable amount of time of being reimbursed for the costs. This was determined to be an isolated incident. Questioned costs include the two invoices that were charged to the grant for this vendor during the year ended September 30, 2023 and were not paid to the vendor within a reasonable amount of time of being reimbursed for the expenditures. Cause/Context: Controls were not in place to ensure expenditures were paid to the vendor prior to requesting reimbursements. This circumstance was determined to be an isolated incident due to the unique nature of the vendor invoices. The Organization was withholding payment to the vendor until it determined that both invoices were proper. Effect: The lack of controls could result in requests for reimbursement being submitted for unpaid expenditures. Recommendation: We recommend the Organization establish procedures and incorporate controls to review that expenditures are paid prior to submitting requests for reimbursement. Views of Responsible Officials and Planned Corrective Actions: The Organization will implement the following changes in its accounting procedures: Each month, an aged open accounts payable report will be produced as part of the month end closing. Invoices that are past due will be paid in the following batch of payments (which are typically run weekly). If it is determined that the invoice is not being paid for a valid reason, it will be removed from accounts payable at that time.
U.S. Department of Justice Crime Victim Assistance – Assistance #16.575 #2023-009 – Major Federal Award Finding – Cash Management Nature of Finding: Compliance Finding Cash Management and Significant Deficiency in Internal Controls over Compliance Criteria/Condition: 2 CFR 200.305 requires that non-federal entities must minimize the time elapsing between the transfer of federal funds to the non-federal entity and the subsequent disbursement of the funds by the non-federal entity for program costs. The Organization did not have proper controls in place to verify that specific vendor invoices were paid within a reasonable amount of time of requesting reimbursement for the expenditures. Questioned Costs: $2,381 Identification of How Questioned Costs Were Computed: The issues of noncompliance related to cash management was limited to one vendor that was not paid within a reasonable amount of time of being reimbursed for the costs. This was determined to be an isolated incident. Questioned costs include the two invoices that were charged to the grant for this vendor during the year ended September 30, 2023 and were not paid to the vendor within a reasonable amount of time of being reimbursed for the expenditures. Cause/Context: Controls were not in place to ensure expenditures were paid to the vendor prior to requesting reimbursements. This circumstance was determined to be an isolated incident due to the unique nature of the vendor invoices. The Organization was withholding payment to the vendor until it determined that both invoices were proper. Effect: The lack of controls could result in requests for reimbursement being submitted for unpaid expenditures. Recommendation: We recommend the Organization establish procedures and incorporate controls to review that expenditures are paid prior to submitting requests for reimbursement. Views of Responsible Officials and Planned Corrective Actions: The Organization will implement the following changes in its accounting procedures: Each month, an aged open accounts payable report will be produced as part of the month end closing. Invoices that are past due will be paid in the following batch of payments (which are typically run weekly). If it is determined that the invoice is not being paid for a valid reason, it will be removed from accounts payable at that time. #2023-010 – Major Federal Award Finding – Period of Performance Nature of Finding: Compliance Finding Period of Performance and Material Weakness in Internal Controls over Compliance Criteria/Condition: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance. The Organization did not have controls in place to verify that costs were being charged to the award in the correct period of performance. Questioned Costs: $20,790 Identification of How Questioned Costs Were Computed: A sample of 40 non-payroll expenditures totaling approximately $48,000 was selected from a population of approximately $552,000 of non-payroll expenditures. An amount of $1,817 combined from two invoices that were charged to the Crime Victim Assistance program was related to the year ending September 30, 2024 and was inappropriately charged to the grant during 2023. Questioned costs are estimated by projecting the error identified in the sample tested to the population of non-payroll expenditures of the Crime Victim Assistance program. Cause/Context: There are not proper controls in place to review invoices and assign them to the appropriate grant period. Two expenditures out of forty non-payroll related expenditures tested for the Crime Victim Assistance grant was for a contracted annual service that covered multiple performance periods but was billed in its entirety to the current fiscal year. Effect: An overstatement of expenditures for the Crime Victim Assistance grant was reported in the current year. Recommendation: We recommend procedures are established to review for proper grant period when recording transactions and creating monthly reimbursement requests. Views of Responsible Officials and Planned Corrective Actions: The Organization will implement the following changes in its accounting procedures. 1. The Staff Accountant will review the period each expenditure is related to and record the invoice to the appropriate period when entering it into accounts payable. The month and year will be noted on the invoice. 2. The CFO will review the month and year noted by the Staff Accountant prior to entry into accounts payable.
U.S. Department of Justice Crime Victim Assistance – Assistance #16.575 #2023-009 – Major Federal Award Finding – Cash Management Nature of Finding: Compliance Finding Cash Management and Significant Deficiency in Internal Controls over Compliance Criteria/Condition: 2 CFR 200.305 requires that non-federal entities must minimize the time elapsing between the transfer of federal funds to the non-federal entity and the subsequent disbursement of the funds by the non-federal entity for program costs. The Organization did not have proper controls in place to verify that specific vendor invoices were paid within a reasonable amount of time of requesting reimbursement for the expenditures. Questioned Costs: $2,381 Identification of How Questioned Costs Were Computed: The issues of noncompliance related to cash management was limited to one vendor that was not paid within a reasonable amount of time of being reimbursed for the costs. This was determined to be an isolated incident. Questioned costs include the two invoices that were charged to the grant for this vendor during the year ended September 30, 2023 and were not paid to the vendor within a reasonable amount of time of being reimbursed for the expenditures. Cause/Context: Controls were not in place to ensure expenditures were paid to the vendor prior to requesting reimbursements. This circumstance was determined to be an isolated incident due to the unique nature of the vendor invoices. The Organization was withholding payment to the vendor until it determined that both invoices were proper. Effect: The lack of controls could result in requests for reimbursement being submitted for unpaid expenditures. Recommendation: We recommend the Organization establish procedures and incorporate controls to review that expenditures are paid prior to submitting requests for reimbursement. Views of Responsible Officials and Planned Corrective Actions: The Organization will implement the following changes in its accounting procedures: Each month, an aged open accounts payable report will be produced as part of the month end closing. Invoices that are past due will be paid in the following batch of payments (which are typically run weekly). If it is determined that the invoice is not being paid for a valid reason, it will be removed from accounts payable at that time.
U.S. Department of Justice Crime Victim Assistance – Assistance #16.575 #2023-009 – Major Federal Award Finding – Cash Management Nature of Finding: Compliance Finding Cash Management and Significant Deficiency in Internal Controls over Compliance Criteria/Condition: 2 CFR 200.305 requires that non-federal entities must minimize the time elapsing between the transfer of federal funds to the non-federal entity and the subsequent disbursement of the funds by the non-federal entity for program costs. The Organization did not have proper controls in place to verify that specific vendor invoices were paid within a reasonable amount of time of requesting reimbursement for the expenditures. Questioned Costs: $2,381 Identification of How Questioned Costs Were Computed: The issues of noncompliance related to cash management was limited to one vendor that was not paid within a reasonable amount of time of being reimbursed for the costs. This was determined to be an isolated incident. Questioned costs include the two invoices that were charged to the grant for this vendor during the year ended September 30, 2023 and were not paid to the vendor within a reasonable amount of time of being reimbursed for the expenditures. Cause/Context: Controls were not in place to ensure expenditures were paid to the vendor prior to requesting reimbursements. This circumstance was determined to be an isolated incident due to the unique nature of the vendor invoices. The Organization was withholding payment to the vendor until it determined that both invoices were proper. Effect: The lack of controls could result in requests for reimbursement being submitted for unpaid expenditures. Recommendation: We recommend the Organization establish procedures and incorporate controls to review that expenditures are paid prior to submitting requests for reimbursement. Views of Responsible Officials and Planned Corrective Actions: The Organization will implement the following changes in its accounting procedures: Each month, an aged open accounts payable report will be produced as part of the month end closing. Invoices that are past due will be paid in the following batch of payments (which are typically run weekly). If it is determined that the invoice is not being paid for a valid reason, it will be removed from accounts payable at that time. #2023-010 – Major Federal Award Finding – Period of Performance Nature of Finding: Compliance Finding Period of Performance and Material Weakness in Internal Controls over Compliance Criteria/Condition: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance. The Organization did not have controls in place to verify that costs were being charged to the award in the correct period of performance. Questioned Costs: $20,790 Identification of How Questioned Costs Were Computed: A sample of 40 non-payroll expenditures totaling approximately $48,000 was selected from a population of approximately $552,000 of non-payroll expenditures. An amount of $1,817 combined from two invoices that were charged to the Crime Victim Assistance program was related to the year ending September 30, 2024 and was inappropriately charged to the grant during 2023. Questioned costs are estimated by projecting the error identified in the sample tested to the population of non-payroll expenditures of the Crime Victim Assistance program. Cause/Context: There are not proper controls in place to review invoices and assign them to the appropriate grant period. Two expenditures out of forty non-payroll related expenditures tested for the Crime Victim Assistance grant was for a contracted annual service that covered multiple performance periods but was billed in its entirety to the current fiscal year. Effect: An overstatement of expenditures for the Crime Victim Assistance grant was reported in the current year. Recommendation: We recommend procedures are established to review for proper grant period when recording transactions and creating monthly reimbursement requests. Views of Responsible Officials and Planned Corrective Actions: The Organization will implement the following changes in its accounting procedures. 1. The Staff Accountant will review the period each expenditure is related to and record the invoice to the appropriate period when entering it into accounts payable. The month and year will be noted on the invoice. 2. The CFO will review the month and year noted by the Staff Accountant prior to entry into accounts payable.
U.S. Department of Justice Crime Victim Assistance – Assistance #16.575 #2023-009 – Major Federal Award Finding – Cash Management Nature of Finding: Compliance Finding Cash Management and Significant Deficiency in Internal Controls over Compliance Criteria/Condition: 2 CFR 200.305 requires that non-federal entities must minimize the time elapsing between the transfer of federal funds to the non-federal entity and the subsequent disbursement of the funds by the non-federal entity for program costs. The Organization did not have proper controls in place to verify that specific vendor invoices were paid within a reasonable amount of time of requesting reimbursement for the expenditures. Questioned Costs: $2,381 Identification of How Questioned Costs Were Computed: The issues of noncompliance related to cash management was limited to one vendor that was not paid within a reasonable amount of time of being reimbursed for the costs. This was determined to be an isolated incident. Questioned costs include the two invoices that were charged to the grant for this vendor during the year ended September 30, 2023 and were not paid to the vendor within a reasonable amount of time of being reimbursed for the expenditures. Cause/Context: Controls were not in place to ensure expenditures were paid to the vendor prior to requesting reimbursements. This circumstance was determined to be an isolated incident due to the unique nature of the vendor invoices. The Organization was withholding payment to the vendor until it determined that both invoices were proper. Effect: The lack of controls could result in requests for reimbursement being submitted for unpaid expenditures. Recommendation: We recommend the Organization establish procedures and incorporate controls to review that expenditures are paid prior to submitting requests for reimbursement. Views of Responsible Officials and Planned Corrective Actions: The Organization will implement the following changes in its accounting procedures: Each month, an aged open accounts payable report will be produced as part of the month end closing. Invoices that are past due will be paid in the following batch of payments (which are typically run weekly). If it is determined that the invoice is not being paid for a valid reason, it will be removed from accounts payable at that time.
U.S. Department of Justice Crime Victim Assistance – Assistance #16.575 #2023-009 – Major Federal Award Finding – Cash Management Nature of Finding: Compliance Finding Cash Management and Significant Deficiency in Internal Controls over Compliance Criteria/Condition: 2 CFR 200.305 requires that non-federal entities must minimize the time elapsing between the transfer of federal funds to the non-federal entity and the subsequent disbursement of the funds by the non-federal entity for program costs. The Organization did not have proper controls in place to verify that specific vendor invoices were paid within a reasonable amount of time of requesting reimbursement for the expenditures. Questioned Costs: $2,381 Identification of How Questioned Costs Were Computed: The issues of noncompliance related to cash management was limited to one vendor that was not paid within a reasonable amount of time of being reimbursed for the costs. This was determined to be an isolated incident. Questioned costs include the two invoices that were charged to the grant for this vendor during the year ended September 30, 2023 and were not paid to the vendor within a reasonable amount of time of being reimbursed for the expenditures. Cause/Context: Controls were not in place to ensure expenditures were paid to the vendor prior to requesting reimbursements. This circumstance was determined to be an isolated incident due to the unique nature of the vendor invoices. The Organization was withholding payment to the vendor until it determined that both invoices were proper. Effect: The lack of controls could result in requests for reimbursement being submitted for unpaid expenditures. Recommendation: We recommend the Organization establish procedures and incorporate controls to review that expenditures are paid prior to submitting requests for reimbursement. Views of Responsible Officials and Planned Corrective Actions: The Organization will implement the following changes in its accounting procedures: Each month, an aged open accounts payable report will be produced as part of the month end closing. Invoices that are past due will be paid in the following batch of payments (which are typically run weekly). If it is determined that the invoice is not being paid for a valid reason, it will be removed from accounts payable at that time. #2023-010 – Major Federal Award Finding – Period of Performance Nature of Finding: Compliance Finding Period of Performance and Material Weakness in Internal Controls over Compliance Criteria/Condition: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance. The Organization did not have controls in place to verify that costs were being charged to the award in the correct period of performance. Questioned Costs: $20,790 Identification of How Questioned Costs Were Computed: A sample of 40 non-payroll expenditures totaling approximately $48,000 was selected from a population of approximately $552,000 of non-payroll expenditures. An amount of $1,817 combined from two invoices that were charged to the Crime Victim Assistance program was related to the year ending September 30, 2024 and was inappropriately charged to the grant during 2023. Questioned costs are estimated by projecting the error identified in the sample tested to the population of non-payroll expenditures of the Crime Victim Assistance program. Cause/Context: There are not proper controls in place to review invoices and assign them to the appropriate grant period. Two expenditures out of forty non-payroll related expenditures tested for the Crime Victim Assistance grant was for a contracted annual service that covered multiple performance periods but was billed in its entirety to the current fiscal year. Effect: An overstatement of expenditures for the Crime Victim Assistance grant was reported in the current year. Recommendation: We recommend procedures are established to review for proper grant period when recording transactions and creating monthly reimbursement requests. Views of Responsible Officials and Planned Corrective Actions: The Organization will implement the following changes in its accounting procedures. 1. The Staff Accountant will review the period each expenditure is related to and record the invoice to the appropriate period when entering it into accounts payable. The month and year will be noted on the invoice. 2. The CFO will review the month and year noted by the Staff Accountant prior to entry into accounts payable.