Finding Text
Finding Number: 2024-001 Repeat Finding: Yes; 2023-001, 2022-001, 2021-001 Federal Program Name/Assistance Listing Title: Federal Transit Cluster Federal Assistance Listing Number: 20.507, 20.526 Federal Agency: U.S. Department of Transportation Federal Award Number: 5339-R-2022-GCTD-00039 Federal Pass-Through Agency: Texas Department of Transportation State Program Name: State Urbanized Area Formula Program, State Formula Grants For Rural Areas State Agency: Texas Department of Transportation Type of Finding: Significant Deficiency in Internal Control Over Compliance Compliance Requirement: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Cash Management Questioned Costs: N/A Criteria District management is responsible for establishing and maintaining effective internal controls over federal awards, and specifically, disbursements and reimbursement requests that are adequate to ensure that all financial activities are properly processed, supported, allowable, and allocable to federal grants in compliance with 2 CFR Part 200. Condition The District lacked proper internal controls over disbursements and reimbursement requests. Cause The District’s internal controls over federal awards, and specifically, disbursements and reimbursement requests were not adequate. Effect The District did not have appropriate controls established over compliance related to disbursements and reimbursement requests in accordance with Federal regulations and District policies related to federal awards. Context The sample was not intended to be, and was not, a statistically valid sample. During our review of disbursements and reimbursement requests, we noted the following: The District does not have a formal system of approval of purchases such as a purchase requisition/purchase order before goods and services are received or rendered. The District does not account for grant expenditures separately in the general ledger. Additionally, the District should lock down months after cash is reconciled and all adjusting entries have been posted. The District did not maintain all monthly supporting documentation for the reimbursements requested from FTA/TxDOT. Based on an initial sample of 40 disbursements reviewed, two (2) disbursements did not have a payment requisition form signed by the Executive Director. Recommendation The District should put a purchase approval process in place before the District’s funds are obligated. The District should ensure the rationale for allocation of expenditures to grants is well documented. Alternatively, the District could record expenditures directly to the grants using a system of fund accounting. Adherence to District policies should be monitored. Noncompliance with policies and procedures should be addressed with employees through additional training. Invoices should be paid in a timely manner to ensure late fees are avoided. If late fees are incurred, they should not be charged to grant funds. Finally, the District should ensure all monthly reports are maintained to support reimbursement requests. Views Of Responsible Officials The District agrees with the finding and has taken steps to address this issue as detailed in the Corrective Action Plan.