Finding 1155510 (2024-003)

Material Weakness Repeat Finding
Requirement
B
Questioned Costs
$1
Year
2024
Accepted
2025-09-26

AI Summary

  • Core Issue: Shatterproof failed to maintain necessary documentation for credit card transactions after changing vendors, leading to significant compliance deficiencies.
  • Impacted Requirements: This affects compliance with 2 CFR Part 200.303, which mandates effective internal controls over federal awards.
  • Recommended Follow-Up: Shatterproof should implement robust internal controls to ensure documentation is retained and accessible during vendor changes, aligning with grant requirements.

Finding Text

Allowable Costs – Nonpayroll Disbursements Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name / Assistance Listing Number / Pass-Through Agency(ies) / Pass-Through Number(s): • Block Grants for Prevention and Treatment of Substance Abuse, 93.959 o Passed through the State of Connecticut, Department of Mental Health and Addiction Services, 24MHA1009 o Passed through the Commonwealth of Pennsylvania, Department of Drug and Alcohol Programs, 4100089071 o Passed through the State of Louisiana, Department of Health, 2000758195 o Passed through the State of Oklahoma, Department of Mental Health and Substance Abuse Services, B08TI083962 & B08TI084602 • COVID-19 - Substance Abuse and Mental Health Services Projects of Regional and National Significance, 93.243 o Passed through the State of California, Department of Health Care Services, 21-10299 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: 2 CFR Part 200.303 (a) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award, Internal Controls requires that the recipient must: “Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the 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).” Shatterproof should have internal controls designed and effectively operating to ensure compliance with those provisions. Condition: Shatterproof changed credit card vendors after March 2024. Documentation of electronic approvals maintained by the prior vendor were not retained or accessible during the audit. Included in these transactions was one instance where supporting documentation for the transaction was not located. Questioned costs: Total questioned costs are $53,632 and are shown by program below: • 93.959 - $7,130 $3,539 State of Connecticut, Department of Mental Health and Addiction Services $1,773 Commonwealth of Pennsylvania, Department of Drug and Alcohol Programs $155 State of Louisiana, Department of Health $1,663 State of Oklahoma, Department of Mental Health and Substance Abuse Services • 93.243 $46,502 State of California, Department of Health Care Services Context: Documentation of electronic approvals maintained by the prior credit card vendor were not retained or accessible during the audit. Documentation for 1 of 80 transactions tested could not be located. Cause: Approvals of credit card transactions are maintained electronically within the vendor’s system. When Shatterproof changed credit card vendors after March 2024 the electronic approvals maintained by the prior vendor were not retained and were no longer accessible by Shatterproof personnel. Effect: The lack of internal controls over these compliance requirements provides an opportunity for noncompliance and questioned costs. Repeat Finding: The finding is a modified repeat of findings in the immediately prior year. Prior year finding numbers were 2023-008 and 2023-009. Recommendation: We recommend Shatterproof ensure internal controls are in place and operating effectively so that when changes in vendors involved in the financial reporting process occur there is an evaluation of the electronic evidence of the performance of internal controls and other data to ensure needed documentation is retained or continues to be accessible in line with their record retention policies and requirements of the grant agreements. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

Allowable Costs – Nonpayroll Disbursements Block Grants for Prevention and Treatment of Substance Abuse – Assistance Listing No. 93.959 COVID-19 - Substance Abuse and Mental Health Services Projects of Regional and National Significance – Assistance Listing No. 93.243 Recommendation: We recommend Shatterproof ensure internal controls are in place and operating effectively so that when changes in vendors involved in the financial reporting process occur there is an evaluation of the electronic evidence of the performance of internal controls and other data to ensure needed documentation is retained or continues to be accessible in line with their record retention policies and requirements of the grant agreements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In April 2024, Shatterproof implemented Bill Spend & Expense (Divvy), a cloud-based platform designed to automate receipt tracking, provide a clear audit trail for expense coding, and support a streamlined approval workflow. Name of the contact person responsible for corrective action: Young Kim Planned completion date for corrective action plan: 4/1/2024

Categories

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring Reporting Significant Deficiency

Other Findings in this Audit

  • 1155495 2024-002
    Material Weakness Repeat
  • 1155496 2024-003
    Material Weakness Repeat
  • 1155497 2024-004
    Material Weakness Repeat
  • 1155498 2024-005
    Material Weakness Repeat
  • 1155499 2024-006
    Material Weakness Repeat
  • 1155500 2024-002
    Material Weakness Repeat
  • 1155501 2024-003
    Material Weakness Repeat
  • 1155502 2024-004
    Material Weakness Repeat
  • 1155503 2024-002
    Material Weakness Repeat
  • 1155504 2024-003
    Material Weakness Repeat
  • 1155505 2024-004
    Material Weakness Repeat
  • 1155506 2024-002
    Material Weakness Repeat
  • 1155507 2024-003
    Material Weakness Repeat
  • 1155508 2024-004
    Material Weakness Repeat
  • 1155509 2024-002
    Material Weakness Repeat
  • 1155511 2024-004
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $4.38M
93.788 Opioid Str $252,457
93.959 Block Grants for Prevention and Treatment of Substance Abuse $227,714
95.010 Congressional Directives $153,802