Finding Text
2023-001 Finding – Federal Award
Type:
Allowable Costs – Significant Deficiency in Internal Control Over Compliance.
Identification of Federal Program:
Head Start Cluster:
AL Number: 93.600 Head Start
Criteria / Requirement:
Allowable costs per 2 CFR section 200.406(a) Applicable Credits, states that to the extent that credits are received
related to allowable costs, they must be credited to the Federal award either as a cost reduction or a cash refund, as
appropriate. The cost principles define credits as purchase discounts, rebates or allowances, recoveries on losses,
insurance refunds, and adjustments of overpayments.
Condition / Context:
During the audit it was brought to our attention that Oregon Child Development Coalition, Inc. earns rewards on a credit
card used in purchasing goods and services utilizing federal dollars. Although the credit card account is held in the
Organization’s name, the individual card is issued utilizing the employee’s name. Per inquiry, it was noted that these
rewards had not been credited as a reduction of costs charged to federal programs. The amount associated with the
rebates has been determined to not be material for the year ended December 31, 2023.
Cause:
Oregon Child Development Coalition’s Credit Card Policy does not address rebates associated with earned rewards
points on credit cards. Policies and procedures are not in place to ensure that the Organization is appropriately
applying credits as a reduction of federal costs.
Effect:
Failure to maintain sufficient policies and procedures for credit cards rebates may result in non‐compliance with the
provisions of applicable requirements of the federal award.
Questioned Costs:
none
Recommendation:
The Organization should establish more defined written policies and procedures regarding credit card rebates that are
in line with Uniform Guidance requirements, as well as establish organizational controls to ensure that such policies
and procedures are being followed.
Management’s response:
Management understands that a significant deficiency in internal controls over compliance has been identified. We
concur with the finding and initiated a Corrective Action Plan to address it. We place the utmost importance on the
summary of the auditor’s results and are working to improve the strength of our internal controls over compliance.