Finding 1157909 (2024-003)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
-
Year
2024
Accepted
2025-09-30

AI Summary

  • Core Issue: The Schedule of Expenditures of Federal Awards (SEFA) lacked required details and contained inconsistencies, complicating the Single Audit process.
  • Impacted Requirements: The SEFA did not meet federal reporting standards under Uniform Guidance, risking noncompliance and increased audit scrutiny.
  • Recommended Follow-Up: Management should establish a tracking system for federal grant expenditures, ensure SEFA accuracy through reconciliation, and train staff on compliance and reporting requirements.

Finding Text

Condition: The Schedule of Expenditures of Federal Awards (SEFA) initially prepared by management did not include the required detail on expenditures incurred under federal programs. The client’s accounting system (QuickBooks) lacked the functionality to effectively track grantfunded expenditures that were capitalized for construction projects, resulting in incomplete reporting. Subsequent versions of the SEFA contained inconsistencies and did not reconcile with supplemental reports or other audit evidence. These limitations increased the complexity of the Single Audit process. Despite these challenges, it remains management’s responsibility to ensure the SEFA is complete, accurate, and prepared in accordance with Uniform Guidance. The issues noted reflect a breakdown in internal controls over federal award reporting and underscore the need for stronger oversight and reconciliation procedures. Cause: The deficiency appears to stem from a combination of system limitations within QuickBooks, which does not natively support federal grant tracking, and a lack of formalized internal processes for identifying and reporting federal expenditures—particularly those capitalized for construction projects. Additionally, there was a misunderstanding of SEFA requirements and insufficient reconciliation between grant activity reports and the SEFA. Effect: The SEFA submitted did not comply with federal reporting requirements under Uniform Guidance, which may increase the risk of noncompliance with federal grant terms and conditions, require expanded audit procedures, and may prompt further scrutiny from oversight bodies. Criteria: Per Uniform Guidance (2 CFR Part 200, Subpart F), entities expending federal funds are required to prepare and submit a SEFA that accurately reflects expenditures by federal program. The SEFA must include total federal expenditures for each award, CFDA numbers (now referred to as Assistance Listing Numbers), and other required details. Revenue listings or unreconciled supplemental reports do not satisfy these requirements. Recommendation: We recommend management implement a system or process to track federal grant expenditures, including capitalized costs, in accordance with Uniform Guidance, prepare the SEFA based on actual expenditures incurred, ensuring reconciliation with supporting documentation, and provide training to relevant personnel on SEFA preparation, federal compliance requirements, and the distinction between revenue and expenditure reporting.

Corrective Action Plan

Management Response: Management concurs with the recommendations and is committed to strengthening its internal controls and compliance with federal grant requirements. It is important to note that the SEFA process for FYE24 was complex due to Work in Process, connected to the St. Elizabeth and Chew Street projects that span multiple years and layered funding sources. Additionally, recent staff transitions did not permit overlap and led to limited but growing clarity relative to funding relationships despite standard operating procedures. To address this finding management will implement the following corrective actions: - Relevant personnel will receive targeted training on SEFA preparation and federal compliance requirements. This will include workshops, updated guidance materials, and ongoing support to ensure consistent and accurate reporting. - Management will enhance its grant tracking processes to ensure that capitalized and noncapitalized expenditures are properly identified and reported. This includes evaluating the current accounting system’s capabilities and implementing supplemental tracking tools where necessary. - A thorough review of prior year data will be conducted to ensure future SEFA submissions are based on expenditure-based reporting and reconcile to supporting documentation. Management will also implement a formal review process prior to SEFA submission to ensure compliance with Uniform Guidance. These actions will be completed prior to preparation of the SEFA for the fiscal year ended December 31, 2025. Management believes these steps will strengthen internal controls, improve compliance, and support the integrity of federal reporting.

Categories

Reporting Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1157908 2024-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
11.307 Economic Adjustment Assistance $2.76M
99.U01 Neighborworks America $526,100
14.218 Community Development Block Grants/entitlement Grants $183,086
14.252 Section 4 Capacity Building for Community Development and Affordable Housing $10,000