Finding 1080110 (2021-001)

Significant Deficiency Repeat Finding
Requirement
B
Questioned Costs
-
Year
2021
Accepted
2024-10-24
Audit: 325873
Organization: Public Defender Association (WA)
Auditor: Clark Nuber P S

AI Summary

  • Core Issue: There is a significant deficiency in internal controls over compliance for allowable costs due to inadequate documentation.
  • Impacted Requirements: Compliance with Title 2 U.S. Code of Federal Regulations requires all costs charged to Federal awards to be properly documented.
  • Recommended Follow-Up: PDA should update its accounting policies to ensure all costs, regardless of amount, have the necessary documentation to meet federal requirements.

Finding Text

Significant deficiency in internal control over compliance for allowable costs related to adequate documentation. Federal Agency: United States Department of Treasury Program Titles: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.019 & 21.027 Pass-Through Entity: King County Award Numbers: 6200091 Award Periods: January 1, 2021 through December 31, 2024 Criteria Internal control requirements contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, Subpart E ‐ Cost Principles, Section 200.400, policy guide, require that a non‐Federal entity ensure that cost be adequately documented to be allowable under Federal awards. The accounting practices of the non-Federal entity must be consistent with cost principles per the policy guide and support the accumulation of costs as required by the principles and must provide for adequate documentation to support costs charged to the Federal award. Condition/Context In our initial sample of transactions for allowability, the PDA said they did not require support for the 24 transactions we had selected under $75 as a policy. They were subsequently able to locate support for all but 8 of these transactions totaling $105. Cause PDA’s accounting policies and practices over allowable costs seemed not properly implemented to ensure compliance with the Uniform Guidance requirements. Effect Some of the transactions were missing adequate documented support. Questioned Costs None. Repeat Finding Yes. Recommendation We recommend that PDA revisits and updates its accounting policies and practices to align with the provisions outlined in the policy guide of the Code of Federal Regulations. Although the current policy may have been established with materiality considerations in mind, it is important to note that all charges to Federal awards necessitate proper documentation, irrespective of the amount involved.

Categories

Allowable Costs / Cost Principles Subrecipient Monitoring Significant Deficiency Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 503666 2021-001
    Significant Deficiency Repeat
  • 503667 2021-001
    Significant Deficiency Repeat
  • 503668 2021-001
    Significant Deficiency Repeat
  • 503669 2021-002
    Material Weakness
  • 503670 2021-002
    Material Weakness
  • 1080108 2021-001
    Significant Deficiency Repeat
  • 1080109 2021-001
    Significant Deficiency Repeat
  • 1080111 2021-002
    Material Weakness
  • 1080112 2021-002
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $4.68M
21.019 Coronavirus Relief Fund $1.13M