Finding Text
Criteria: The Foundation is responsible for implementing policies, including internal controls, that
are designed to provide reasonable assurance regarding the achievement of the following objectives:
effectiveness and efficiency of operations, reliability of reporting for internal and external use; and
compliance with applicable laws and regulations. Per 2 CFR 180.300 and 200.318-200.326, the
Foundation is responsible for implementing policies and procedures before entering into covered
transactions with vendors as well as performing competitive bidding procedures for vendors used in
federal award spending.
Condition: The overall process for tracking federal funds spent and the reimbursement process is a
manual process performed by one department. For majority of the year the Foundation lacked formal
policies for reimbursement, procurement and timely review of calculations throughout the year.
Cause: The Foundation saw increased levels of federal funding during the previous year and did not
have the process in place to ensure compliance until majority of the way through the year.
Effect: The lack of process documentation and review process limited the Foundation’s ability to
design and implement the necessary internal controls over compliance with federal awards.
Questioned Costs: Indeterminable.
Context: The finding represents a systematic deficiency in the Foundation’s process surrounding
federal funds. This finding cannot be quantified in terms of dollar value.
Repeat Finding: This is partially a repeat finding as the Foundation implemented the required policies
during the year ended December 31, 2024.
Recommendation: We recommend increased training in federal grant compliance and specific grant
requirements. Additionally, the Foundation should continue to review and implement formal
processes surrounding federal funds and the review of reimbursement requests.
Views of Responsible Officials: Management concurs with the finding and implemented a
comprehensive procurement policy in October 2024 compliant with federal regulations under the
Uniform Guidance (2 CFR Part 200), with full staff training completed and internal monitoring
controls established.