Finding 1137437 (2023-008)

Significant Deficiency
Requirement
A
Questioned Costs
-
Year
2023
Accepted
2025-05-19
Audit: 356632
Organization: Heading Home (NM)

AI Summary

  • Core Issue: Lack of documented approval for federal expense disbursements, with 11 out of 11 transactions missing proper documentation.
  • Impacted Requirements: Non-compliance with internal control policies and federal grant management standards, increasing risk of unauthorized expenditures.
  • Recommended Follow-Up: Reinforce approval policies, retrain staff, and implement periodic reviews and automated checks to ensure compliance before processing payments.

Finding Text

2023-008 – LACK OF DOCUMENTED APPROVAL FOR FEDERAL EXPENSE DISBURSEMENTS Type of Finding: (F) – Significant Deficiency in Internal Control Over Compliance of Federal Awards Funding Agency: U.S. Department of the Treasury Title: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds AL #: 21.027 Award #: 202300279, 202300281, 202300280, 202300455 Award Period: July 1, 2022 – June 30, 2023 Questioned Costs: None Statement of Condition During testing of federal expense disbursements, it was noted that non-payroll transactions did not contain proper documentation of approvals. Context During our testing of internal controls over compliance, it was noted that 11 out of all 11 sampled non-payroll transactions did not include documentation of approval from an appropriate official. No non-compliance was noted. Criteria According to the organization's internal control policy and federal grant management standards 2 CFR § 200.303 Internal Controls during testing of Allowable Activities/Unallowable Activities, “The recipient and subrecipient must (a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Cause High turnover in the accounting department and an increase in transaction volume negatively impacted the documentation of approvals by an appropriate official. Effect Failure to maintain documented approvals for federal disbursements increases the risk of unauthorized or improper expenditures, which could lead to questioned costs, potential disallowance of federal funding, and reputational harm. It also represents a breakdown in internal control over financial reporting and compliance. Recommendation We recommend that management reinforce existing policies requiring documented approval by appropriate officials for all disbursements. Departments should be retrained on the approval requirements, and periodic reviews should be implemented to ensure compliance. Additionally, the finance department should implement a checklist or automated control to verify that documented approval is present before processing payments. View of Responsible Official and Corrective Action Plan Heading Home management is in agreement with this finding. Management has reviewed the existing policies and procedures found in Section II Policy #201 of Heading Homes fiscal policies and procedures with appropriate staff and will enforce the policies and procedures to ensure all invoices and funds requests are properly reviewed and approved prior to processing. All invoices and requests for funds for fiscal year 2024 will be reviewed to ensure the payment request is reasonable and necessary. The invoice or funds request will be signed and dated by the preparer, as well as by the reviewer as evidence of approval for processing the payment. All invoices and funds requests will be maintained in the cloud server in a manner that allows them to be easily retrieved when needed. The disbursements in question were reviewed and found to be to vendors regularly used by Heading Home and Heading Home firmly believes that documentation of approval existed at one point in time. However, with the complete turnover in executive personnel during 2023, and the fact that the prior administration utilized an online system for document storage that the current administration has very little access to, we were unable to locate the approvals for these payments. Management anticipates the above corrective action plan to be fully implemented by June 30, 2024. Personnel responsible for ensuring implementation include Connie Chavez, Chief Executive Officer, Debbie Brickman, Chief Financial Officer, and Armando Sanchez, contract accountants team lead.

Categories

Subrecipient Monitoring Allowable Costs / Cost Principles Reporting Significant Deficiency Internal Control / Segregation of Duties

Other Findings in this Audit

  • 560973 2023-004
    Significant Deficiency Repeat
  • 560974 2023-004
    Significant Deficiency Repeat
  • 560975 2023-004
    Significant Deficiency Repeat
  • 560976 2023-004
    Significant Deficiency Repeat
  • 560977 2023-004
    Significant Deficiency Repeat
  • 560978 2023-005
    Significant Deficiency Repeat
  • 560979 2023-005
    Significant Deficiency Repeat
  • 560980 2023-005
    Significant Deficiency Repeat
  • 560981 2023-005
    Significant Deficiency Repeat
  • 560982 2023-005
    Significant Deficiency Repeat
  • 560983 2023-006
    - Repeat
  • 560984 2023-006
    - Repeat
  • 560985 2023-006
    - Repeat
  • 560986 2023-006
    - Repeat
  • 560987 2023-006
    - Repeat
  • 560988 2023-006
    - Repeat
  • 560989 2023-006
    - Repeat
  • 560990 2023-006
    - Repeat
  • 560991 2023-006
    - Repeat
  • 560992 2023-006
    - Repeat
  • 560993 2023-008
    Significant Deficiency
  • 560994 2023-008
    Significant Deficiency
  • 560995 2023-008
    Significant Deficiency
  • 560996 2023-008
    Significant Deficiency
  • 1137415 2023-004
    Significant Deficiency Repeat
  • 1137416 2023-004
    Significant Deficiency Repeat
  • 1137417 2023-004
    Significant Deficiency Repeat
  • 1137418 2023-004
    Significant Deficiency Repeat
  • 1137419 2023-004
    Significant Deficiency Repeat
  • 1137420 2023-005
    Significant Deficiency Repeat
  • 1137421 2023-005
    Significant Deficiency Repeat
  • 1137422 2023-005
    Significant Deficiency Repeat
  • 1137423 2023-005
    Significant Deficiency Repeat
  • 1137424 2023-005
    Significant Deficiency Repeat
  • 1137425 2023-006
    - Repeat
  • 1137426 2023-006
    - Repeat
  • 1137427 2023-006
    - Repeat
  • 1137428 2023-006
    - Repeat
  • 1137429 2023-006
    - Repeat
  • 1137430 2023-006
    - Repeat
  • 1137431 2023-006
    - Repeat
  • 1137432 2023-006
    - Repeat
  • 1137433 2023-006
    - Repeat
  • 1137434 2023-006
    - Repeat
  • 1137435 2023-008
    Significant Deficiency
  • 1137436 2023-008
    Significant Deficiency
  • 1137438 2023-008
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $128,185
14.231 Emergency Solutions Grant Program $39,233
16.838 Comprehensive Opioid Abuse Site-Based Program $5,775