Finding Text
2023-001 Twenty-First Century Community Learning Centers – Assistance Listing No. 84.287
Significant Deficiency in Internal Control Over Compliance and Noncompliance – Appropriate Internal
Control Structure Related to Compliance Requirements
A. Activities Allowed or Unallowed, B. Allowable Costs/Cost Principles, and C. Cash Management
Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost
Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-Federal entities
receiving Federal funds to have certain written policies, procedures, and standards of conduct (policies) in place.
Condition and Context: The Organization does not have the written policies in place in accordance with §200.302
Financial Management paragraph (b)(6) and (b)(7), which requires written procedures for determining the
allowability of costs in accordance with Subpart E of the Uniform Guidance and the terms and conditions of the
federal award.
Cause and Effect: As the policies referenced above are not written, the Organization is not in compliance with the
requirements. In addition, lack of written policies related to federal awards may lead to noncompliance with other
federal requirements and the terms and conditions of federal awards.
Recommendation: We recommend the policies in accordance with §200.302 Financial Management paragraph
(b)(6) and (b)(7) be written by the Organization, approved by the Board of Directors, and included in the
permanent files of BGCH.
Views of Responsible Officials and Planned Corrective Action: We agree with the recommendation and plan to
have the corrective action implemented by December 31, 2024. Boys & Girls Club of Huntington has always
followed the Twenty-First Century Community Learning Centers policy on activities allowed or unallowed, but had
not put a written policy in place to recognize this, so will create the written policy and have it approved by the end
of 2024.