Finding Text
Finding 2023-002: Significant Deficiency in Internal Control over Compliance: Approval of Executive Director’s Expenditures
Information on the Federal Program: Assistance Listing Number 16.557 - Office on Violence Against Women: Tribal Domestic Violence and Sexual Assault Coalitions Program, award numbers: 15JOVW-22-GG-03618-MUMU, 15JOVW-21-GG-02267-MUMU
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 and most of 2023.
Effect or Potential Effect: Unallowable costs or activities could be charged to federal grants.
Questioned Cost: None
Context: As of the date of testing, documented approval was not available for two of forty items selected ($1,730 of $67,177) for assistance listing 16.557.
Repeat finding: Yes, 2022-002
Recommendation: We recommend the Organization obtain approval of Executive Director’s expenses by a Circle Keeper (board member) prior to the expenses being charged to a federal grant.
Planned Corrective Action: It was determined during the 2022 audit that expenditures initiated by the Executive Director did not have the required approval. At the time of the 2022-002 finding, an update was made to the procedures in the Financial Policies and Procedures manual Part III, Sections 2 and 4 to address the use of MIWSAC credit/debit cards for expenditures. This update was included with the corresponding corrective action plan in August 2023.
The Executive Director’s credit/debit card purchases and expense reimbursement requests are now approved by the Keeper of Finances or the Keeper of Traditional Ways.
This corrective action was fully implemented November 1, 2023.