Finding Text
Findings and Questioned Costs Relating to Federal Awards
2024 001 SEFA Control Deficiency
U.S. Department of Treasury
Community Development Financial Institutions Program (ALN 21.033)
Statistically Valid Sample: No, and it was not intended to be.
Prior Year Finding: Not a repeat finding.
Finding Type: Significant deficiency
Criteria
CFR 200.502(a) requires expenditures be recorded in the period they occur.
Additionally, 2 CFR 200.303(a) states that non federal entities must establish and maintain effective internal control over federal awards that provide reasonable assurance that the non federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Condition and Context
During our test work over the Schedule of Expenditures of Federal Awards (SEFA), we noted the Organization incorrectly reported expenditures, in the amount of $693,023, incurred in the fiscal year ended September 30, 2023 on the 2024 SEFA. CFR 200.502(a) requires expenditures be recorded on the SEFA in the period they occur. The 2023 expenditures were incurred during the performance period of the grant and were for activities allowed under the grant, therefore there were no questioned costs or noncompliance related to the expenditures. The Organization’s internal controls were not designed to detect that the expenditures were not timely reported on the SEFA.
Cause
The significant deficiency arose primarily from a misunderstanding and misapplication of SEFA preparation rules in accordance with CFR 200.502(a), specifically regarding the timing of recording expenditures.
Effect
Failure to properly report expenditures on the SEFA can lead to a missed or incorrect major program determination.
Questioned Costs
None.
Recommendation
We recommend that the Organization strengthen its internal controls to ensure all expenditures are reported on the SEFA in the period incurred to comply with the requirements of CFR 200.502(a).
Views of Responsible Officials
As noted by our auditor, the submitted expenditures were allowable under the grant. The condition exists such that these expenditures were included within the current period SEFA report because that is when they were determined to be applicable, rather than the period when they were actually incurred (the prior period SEFA report). Going forward, management will ensure to report expenditures in the period they were incurred rather than the period they were applied.