Finding Text
2023-003 Internal Controls System Over Allowable Costs and Allowed Activities. – U.S. Department of Housing and Urban Development, Housing Opportunities for Persons with AIDS, Assistance Listing Number 14.241, Passed Through the City of Las Vegas, Nevada.
Criteria: As defined in 2 CFR 200.303, auditee is required to maintain a system of internal control over compliance designed to provide reasonable assurance that federal award transactions executed are in compliance with the terms and conditions of the federal award. Funds utilized under the Housing Opportunities for Persons with AIDS program are required to be expended on costs consistent with those outlined in 2 CRF 200 Subpart E – Cost Principles, and within the core service categories outlined in the grant agreement.
Condition: Of the fourteen request for reimbursement (RFR) forms prepared and submitted to the grantor in order to receive reimbursement for expenditures during the year, seven were not reviewed and signed by the Executive Director. AFAN has designed a control such that a review of each RFR is performed to ensure expenditures are for allowable costs and allowable activities allowed for under the grant. However, this control was not performed consistently.
Cause: The internal control system over the assessment of allowable costs and allowed activities was not operating effectively. A review of requests for reimbursement was either not performed or documentation was not maintained to support a review of requests for reimbursement.
Context: Management failed to consistently perform an internal control to address the risk of improper expenses being submitted for reimbursement by the Organization’s grant.
Effect: Not performing a review over the documents and allocations supporting requests for reimbursement for the grant increases the risk that unallowable costs and unallowable activities could be submitted for reimbursement which could result in noncompliance of the terms of the federal grant agreement.
Repeat Finding: No
Recommendation: We recommend management design and implement a system of internal controls whereby a review of costs and activities and the related supporting schedules being submitted for reimbursement are reviewed on a consistent basis and management ensures proper documentation of this review is maintained to support the performance of the control.
Views of Responsible Officials and Planned Corrective Actions: Management will implement a control whereby the Executive Director will review and sign all requests for reimbursement prepared by the Finance Manager for submission. The Executive Director will ensure all backup is included and that all direct costs are approved and allowable prior to submission. Payroll related reimbursements will be reviewed to ensure the individuals included and allocation amongst grants are appropriate and the allocations agree to the final payroll records.