Finding Text
Assistance Listing, Federal Agency, and Program Name - 11.611, United States Department of Commerce (DOC), National Institute of Standards and Technology (NIST)
Federal Award Identification Number and Year - 70NANB20H067
Finding Type - Significant deficiency
Repeat Finding - No
Criteria - Internal controls should be put in place to ensure grant duties are appropriately segregated between preparation and review processes.
In addition, written procdures to implement cash management requirements should in place and updated in accordance with 2 CFR Part 200.305.
Condition - The Organization did not have appropriate segregation of duties surrounding the preparation and review of the monthly NIST schedules which accumulate the information necessary to calculate allowable costs and matching for drawdown requests.
Further, while the Organization had written procedures over cash management, they were outdated and did not reflect the current staffing model.
Questioned Costs - Not applicable
Context - One individual was responsible for the preparation of the monthly schedule described above and submission of the drawdown request.
The cash management policy was not updated when there was restructuring in the finance department during fiscal year.
Cause and Effect - Turnover within the finance department contibuted to the lack of segregation of duties and delay in updating the cash management policy. A lack of segregation of duties allows for the potential for errors and/or noncompliance to occur without detection. The outdated cash management policy was not reflective of the actual process.
Recommendation - An individual independent of the preparation process should review and approve the information used to calculate allowable costs and matching prior to submitting the drawdown requests for cash management. Additionally, the cash management policy should be updated to reflect the new process.
Views of Responsible Officials and Planned Corrective Actions - Subsequent to year end, the reorganized finance team put new controls and procedures in place.
Moving forward the Accounting Supervisor will calculate the NIST MEP monthly program income which is used to determine the monthly award drawdown of cash from the available grant award funds. This is reviewed by the Controller and this report is used to create SF 425.