Finding Text
Criteria: The Organization must (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that they are managing the Federal award in compliance with Federal statues, 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: New Hampshire Department of Education (NHED) identified certain policies in its federal fiscal monitoring report dated November 28, 2023 that either needed updating or needed to be created. During our own audit procedures for the year ended December 31, 2023, we too noted certain of these policies lacking. Cause: The Organization does not have a dedicated accounting or grant management personnel. Effect: The Organization did not adequately establish and maintain effective internal controls. The lack of internal controls is non-compliant with 2 CFR 200.303, which could lead to additional compliance concerns and questioned costs. Questioned Costs: None Repeat finding: The same finding was reported during the program specific audit as of and for the year ended December 31, 2022 as 2022-002. Recommendation: We recommend updating policies and procedures to include the requirements of Federal rules and laws for those transactions or activities that include Federal grant funds. As per NHED’s federal fiscal monitoring report, at a minimum, the following policies and procedures need to be created, updated, and/or implemented by the school: 1. Procurement Policy in accordance with updated 2 CFR 200.317-327. 2. Procurement Procedure in accordance with 2 CFR 200.317-327. 3. Time and Effort Procedure in accordance with 2 CFR 200.431. 4. Drug Free Workplace Policy in accordance with 34 CFR 84.200 and Drug Free Workplace Act of 1988 5. Inventory Management Procedure in accordance with 2 CFR 200.313(d) Views of Responsible Officials: All policies and procedures have since been vetted by an attorney and approved by the Board. The Executive Director will ensure that all policies and procedures stay current and are reviewed by the Board annually.