Finding 1157133 (2024-002)

Material Weakness Repeat Finding
Requirement
AB
Questioned Costs
-
Year
2024
Accepted
2025-09-30
Audit: 369464
Auditor: Sikich CPA LLC

AI Summary

  • Core Issue: The Organization exceeded approved budget amounts for certain categories without prior approval, violating federal cost principles.
  • Impacted Requirements: Expenditures must comply with 2 CFR Part 200, Subpart E, and any budget revisions require prior written approval as per 2 CFR § 200.308.
  • Recommended Follow-Up: Strengthen internal controls to ensure compliance with budget limits and federal regulations on allowable costs.

Finding Text

2024-002: Significant Deficiency: Activities Allowed or Unallowable Costs/Cost Principles Criteria: In accordance with federal regulations, expenditures charged to federal awards must comply with the allowable cost principles outlined in 2 CFR Part 200, Subpart E. Furthermore, recipients and subrecipients are required to operate within the parameters of the approved budget as specified in the grant agreement. Any budgetary revisions must receive prior written approval from the awarding federal agency or pass-through entity, pursuant to 2 CFR § 200.308. Section III: Federal Award Findings and Questioned Costs (Continued) 2024-002: Significant Deficiency: Activities Allowed or Unallowable Costs/Cost Principles (Continued) Condition: During our audit procedures, we noted that the Organization incurred expenditures in excess of the approved amounts within certain budget categories. The reallocation of funds between these categories exceeded the allowable threshold of 10%, as stipulated in the grant agreement, without obtaining the required prior approval. Cause: The Organization’s internal controls over compliance related to the review and reconciliation of budgeted amounts against actual expenditures charged to the grant were not adequately designed or implemented to detect and prevent variances. Effect: As a result, costs submitted for reimbursement exceeded the approved budgetary limits for certain budget line items established in the grant agreement, rendering a portion of the expenditures unallowable under federal regulations. Questioned Costs: None Recommendation: We recommend that the Organization’s management evaluate and strengthen internal control over compliance procedures to ensure expenditures consistently comply with federal cost principles and remain within approved budget line items. Views of Responsible Officials: Management agrees with this finding and their response is included in the corrective action plan.

Corrective Action Plan

The purchase of the grant management system will interface directly with the organization’s accounting software, allowing for the automated extraction of financial data. This data will be systematically mapped to the corresponding budgetary lines of each grant to ensure accurate tracking and reporting. On a monthly basis, the Financial Grant Coordinator will collaborate with Senior Directors and Program Directors to review financial activity. These reviews aim to verify that expenditure aligns with the allowable costs defined by each grant, ensuring full compliance with funding requirements. Corrective: Budget vs. actual reviews are conducted with senior directors to evaluate financial performance and ensure alignment with programmatic, administrative, and funding guidelines. During these reviews, directors assess which costs are permissible and identify any expenditure that falls outside allowable parameters. Non-compliant costs are reallocated to appropriate programs that permit such expenses or to administrative accounts as necessary.

Categories

Allowable Costs / Cost Principles Subrecipient Monitoring

Other Findings in this Audit

  • 1157132 2024-001
    Material Weakness Repeat
  • 1157134 2024-003
    Material Weakness Repeat
  • 1157135 2024-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.215 Innovative Approaches to Literacy; Promise Neighborhoods; Full-Service Community Schools; and Congressionally Directed Spending for Elementary and Secondary Education Community Projects $1.06M
16.827 Justice Reinvestment Initiative $280,000
84.287 Twenty-First Century Community Learning Centers $258,795
21.027 Coronavirus State and Local Fiscal Recovery Funds $231,577
84.424 Student Support and Academic Enrichment Program $72,594
97.024 Emergency Food and Shelter National Board Program $11,133
14.218 Community Development Block Grants/entitlement Grants $10,830