Finding 1054326 (2022-002)

Significant Deficiency
Requirement
AB
Questioned Costs
-
Year
2022
Accepted
2024-07-08

AI Summary

  • Core Issue: There is a significant deficiency in internal controls regarding the approval of the Executive Director’s expenditures.
  • Impacted Requirements: Compliance with 2 CFR 200.3030 is lacking, specifically in ensuring timely approvals for expenditures initiated by the Executive Director.
  • Recommended Follow-Up: Implement regular reviews of Executive Director expenses by a Circle Keeper and update the Financial Policies and Procedures manual accordingly.

Finding Text

Significant Deficiency in Internal Control over Compliance: Approval of Executive Director’s Expenditures. Information on the Federal Program: Assistance Listing Number 16.526 ‐ Office on Violence Against Women: Training and Technical Assistance Initiative and 16.557 Office on Violence Against Women: Tribal Domestic Violence and Sexual Assault Coalitions Program Award Numbers: 15JOVW‐21‐GG‐02267‐MUMU, 2018‐TA‐AX‐K002 Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs and Cost Principles Type of Finding: Significant deficiency in internal control over compliance. Criteria: 2 CFR 200.3030 of Subpart D, “Post Federal Award Requirements Standards for Financial Program Management,” of the Uniform Guidance requires a nonfederal entity to establish and maintain effective internal control over the federal award that provides reasonable assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award, including Activities Allowed or Unallowed and Allowable Costs and Cost Principles. Condition: Processes and procedures in place to approve expenditures did not include timely approval of expenses initiated by the Executive Director. Cause: The Executive Director or Operations Director approves all expenditures, however a process was not in place for a Circle Keeper (board member) to regularly review expenditures initiated by the Executive Director during 2022. Effect or Potential Effect: Unallowable costs or activities could be charged to federal grants. Questioned Cost: None Context: One of eleven items selected ($252 of $23,074 direct expenses tested) for assistance listing 16.526 and one of twenty‐four items selected ($377 of $21,809 direct expenses tested) for assistance listing 16.557 had not been approved as of the date of testing. Recommendation: We recommend the Organization provide evidence of the Executive Director’s expenses to a Circle Keeper for approval on a regular basis.Responsible Official’s Response: Agree. The two expenditures initiated by the Executive Director that did not have the required approval of the Keeper of Finances was an oversight and not in line with the Financial Policies and Procedures. We have determined an update is necessary to the procedures in the Financial Policies and Procedures manual to address the use of MIWSAC credit/debit cards for expenditures. We have updated Part III, Sections 2 and 4, which is included with the corrective action. Further, we will request the Circle Keepers to adopt these changes to the Financial Policies and Procedures at their next scheduled meeting. And, we will advise staff of the expense approval oversights revealed by the audit along with the updated procedures added to the Financial Policies and Procedures manual. This communication will be provided in writing as a memo to all staff.

Categories

Allowable Costs / Cost Principles Internal Control / Segregation of Duties

Other Findings in this Audit

  • 477884 2022-002
    Significant Deficiency
  • 477885 2022-002
    Significant Deficiency
  • 477886 2022-002
    Significant Deficiency
  • 477887 2022-002
    Significant Deficiency
  • 477888 2022-002
    Significant Deficiency
  • 477889 2022-002
    Significant Deficiency
  • 477890 2022-001
    Material Weakness
  • 477891 2022-001
    Material Weakness
  • 477892 2022-001
    Material Weakness
  • 477893 2022-001
    Material Weakness
  • 477894 2022-001
    Material Weakness
  • 477895 2022-001
    Material Weakness
  • 1054327 2022-002
    Significant Deficiency
  • 1054328 2022-002
    Significant Deficiency
  • 1054329 2022-002
    Significant Deficiency
  • 1054330 2022-002
    Significant Deficiency
  • 1054331 2022-002
    Significant Deficiency
  • 1054332 2022-001
    Material Weakness
  • 1054333 2022-001
    Material Weakness
  • 1054334 2022-001
    Material Weakness
  • 1054335 2022-001
    Material Weakness
  • 1054336 2022-001
    Material Weakness
  • 1054337 2022-001
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
16.557 Tribal Domestic Violence and Sexual Assault Coalitions Grant Program $186,839
16.841 Voca Tribal Victim Services Set-Aside Program $172,735
16.027 National Clearinghouse on Sexual Assault of American Indian and Alaska Native Women $106,716
16.575 Crime Victim Assistance $18,162
16.526 Ovw Technical Assistance Initiative $11,997
93.496 Family Violence Prevention and Services/culturally Specific Domestic Violence and Sexual Violence Services $1,047