Finding Text
Federal Agency: Department of Justice
Federal Program Name: Services for Victims of Human Trafficking
Assistance Listing Number: 16.320
Federal Award Identification Number and Year: 2020-VT-BX-0080, 2020-VM-BX-0003,
15POVC-23-GG-04086-HT, 15POVC-23-GG-02751-MINO, 15POVC-22-GG-03897-HT,
15POVC-21-GG-03694-HT, and 2020-HT-OVC-614
Award Period: October 1, 2020 through September 30, 2026
Type of Finding:
• Material Weakness in Internal Control over Compliance
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of allowable costs. The Organization should have internal controls designed to ensure compliance with those provisions.
Condition: Internal controls over compliance for allowable costs were not in place to support that the Organization was requesting reimbursement for costs allowable by the Federal Agency.
Questioned costs: None
Context:
Indirect Allocations
In a sample of 17, 15 of the draw down requests were made based on expected expenses, however, 12 out of the 15 draw requests resulted in actual expenses incurred exceeding the amount drawn. 3 out of the 15 were draw requests made in advance of expenses incurred or to catch up on expenses incurred not previously drawn down on.
Cause: The Organization was in its startup phases and was struggling to maintain current operations with limited staff.
Effect or potential effect: The amounts reimbursed by the Federal Agency may by unallowable and result in a refund to the Federal Agency.
Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2022-004.
Recommendation: We recommend the Organization design controls to ensure the draw down requests and related support are formally reviewed and approved by the Executive Director for allowability before submitting the request to the awarding agency.
Views of responsible officials: We agreed with the above comment. The Organization will put a formal layer of review after preparation of the draw down request and support and before submission to the awarding agency and make sure the approved support is kept on file.