Finding Text
Finding 2024-002 – Activities Allowed/Unallowed, Costs Principles, and Period of Performance (Internal Controls Over Compliance) (Repeat Finding 2023-001)
Material Weakness
Criteria:
Uniform Guidance 2 CFR, Part §200.313(a) requires that non-federal entities must establish and maintain effective internal control over the Federal award that provides 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. These internal controls should be in compliance with 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).
Condition:
During our review of the Coalition’s disbursements related to the Title V major program, we examined 68 transactions for internal controls over compliance. 7 of the 68 transactions examined did not contain sufficient evidence that a review and approval process was completed prior to payment being processed.
Questioned Costs:
None
Cause:
The Coalition does not have sufficiently established control policies and procedures to ensure proper approvals are obtained prior to the disbursement transactions being processed.
Effect:
Disbursements are being processed without proper approval, resulting in the possibility of disallowed expenditures.
Recommendation:
We recommend the Coalition becomes familiar with requirements of 2 CFR, Part §200.313(a) and establishes appropriate internal control policies and procedures and that all staff be trained on those policies and procedures, so they are familiar with the requirements. We further recommend the Coalition does not process payment for disbursements that do not contain necessary approvals.
Views of Responsible Officials:
See the corrective action plan that accompanies the schedule of findings and questioned costs.