Finding 1076180 (2023-003)

Criteria: According to 2 CFR 200.303(a), Organizations must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our testing of cash draws, it was noted that the same individual was preparing, reviewing, and initiating cash draws for the Organization. A similar situation was noted in our testing of internal controls over reporting in that the same individual was preparing, reviewing, and submitting the financial reports. Cause: Per discussion with Management, due to turnover and transitions within the accounting department and outsourced accountants there was a period of time where segregation of duties was not maintained. Effect: The internal controls over cash draws and reporting were not in compliance with federal guidelines. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Organization take steps to ensure proper segregation of duties and implement alternatives if or when sufficient staffing is not available in traditional roles.