Finding Text
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: ACL Centers for Independent Living
Assistance Listing Number: 93.432
Federal Award Identification Number and Year:
2004WAILC3 - 2021
2006WAILC3 - 2021
2104WAILCL - 2022
2106WAILCL - 2022
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period:
2004WAILC3 - 4/1/2020-9/30/22
2006WAILC3 - 4/1/20-9/30/22
2104WAILCL - 9/30/21-9/29/23
2106WAILCL - 9/30/21-9/29/23
Type of Finding:
Cash Management
• Material Weakness in Internal Control over Compliance
Criteria or specific requirement: Per 2 CFR 200.302(b)(3) the nonfederal entity must keep "records that identify adequately the source and application of funds for federally-funded activities" and must maintain effective controls over these procedures.
Condition: No accompanying invoices to support drawdown requests.
Questioned costs: None
Context: While there existed evidence of supporting invoices for Federal expenditures (with the exception of one item for $52 - see finding 2022-006), these were not compiled into an auditable list showing justification for the drawdown amounts. Auditors reviewed the profit and loss schedule for the year and were not able to identify a clear pattern between expenditures and drawdowns.
Cause: Lack of procedures requiring supporting documentation.
Effect: Reimbursement requests could be made for unallowed expenditures.
Repeat Finding: No
Recommendation: Implement process to ensure documentation is kept identifying which expenditures are included in reimbursement request. There should be a secondary individual (ED and contract accountant) involved in the process to ensure accuracy - documentation of the two-person preparation and review process should be documented. Implement procedures to document review of subrecipient payment requests and minimize time elapsed between requests and payments.
Views of responsible officials: There is no disagreement with the audit finding.