Finding 1160352 (2023-002)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
-
Year
2023
Accepted
2025-10-13
Audit: 370737
Organization: Legal Aid of Northwest Texas (TX)

AI Summary

  • Core Issue: The federal assistance listing number (FALN) was not updated, leading to a compliance finding related to the reporting of COVID-19 funds.
  • Impacted Requirements: Entities must accurately report federal financial assistance on the SEFA, including the correct FALN and amounts passed to sub-recipients.
  • Recommended Follow-Up: Implement review procedures to ensure all funding sources are updated to reflect the correct financial assistance listing numbers on the SEFA.

Finding Text

Finding 2023-002 Major Federal Program: 21.027 - COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Compliance Requirements: Reporting Criteria: Entities are required to report federal financial assistance on the Schedule of Expenditures of Federal Awards (SEFA), including the federal assistance listing number (FALN) and amounts passed through to sub-recipients. Condition: (X) Compliance Finding (X) Significant Deficiency ( ) Material Weakness Context: The FALN carried forward from the previous contract year was not updated to reflect a change in the grantor’s funding source from 16.575 – Crime Victims Assistance – Rural Safe at Home Project to 21.027 – COVID-19: Coronavirus State and Local Fiscal Recovery Funds. Effect and Questioned Costs: One revised, the SEFA properly reflected $1,617,909 of expenditures under Coronavirus State and Local Fiscal Recovery Funds (FALN 21.027). As a result of the revision, FALN 21.027 was required to be audited as a major program and required reissuance of the audit report. The testing of the direct and material compliance requirements for FALN 21.027 resulted in no additional compliance or controls over compliance findings. Likely questioned costs were indeterminable. Recommendation: We recommend review procedures be put in place to ensure that all funding sources from grantors are updated to properly reflect the applicable financial assistance listing numbers on the SEFA. Response: See Corrective Action Plan.

Corrective Action Plan

Finding 2023-002 Major Federal Program: 21.027 - COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Compliance Requirements: Reporting Response: LANWT acknowledges that the SEFA initially submitted to the auditors included a clerical error in the FALN classification for Contract #1696416. The $1,617,909 in expenditures was inadvertently reported under FALN 16.575 rather than the correct FALN 21.027 in the SEFA spreadsheet. However, the expenditures were allowable, properly documented, and fully supported by the grant agreement, which was provided to the auditors during fieldwork. LANWT respectfully disagrees with the classification of this matter as a compliance finding and significant deficiency. The misclassification did not involve any questioned costs, noncompliance with the grant terms, or omission of federal expenditures. The auditors had access to the source grant documentation, which clearly identified the correct FALN. In our view, this error was a joint oversight that resulted in a SEFA presentation correction, not a failure in internal control or compliance. Corrective Action: To prevent recurrence, LANWT has strengthened its SEFA preparation process by implementing the following procedures: All SEFA entries are now reviewed against source grant agreements by two independent finance staff members prior to submission. A checklist has been introduced to confirm correct ALNs and funding sources before SEFA finalization. Internal training has been conducted on SEFA requirements, including proper identification and reporting of federal assistance listing numbers. In future audits, LANWT will also request that the audit firm verify that the ALN and program name recorded on the SEFA are consistent with those identified in the source grant agreements, which are made available to the auditors during field work. The Chief Financial Officer (CFO) is responsible for ensuring the implementation and ongoing oversight of these corrective actions. LANWT remains committed to accurate and compliant reporting and appreciates the opportunity to clarify this matter. Date of Completion: June 20, 2025 Person Responsible to Ensure Completion: Bhuvana Kannan, CFO

Categories

Reporting

Other Findings in this Audit

  • 1160351 2023-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
09.U01 Basic Field Grant $12.00M
21.023 Emergency Rental Assistance Program $2.79M
93.568 Low-Income Home Energy Assistance $556,330
16.575 Crime Victim Assistance $541,788
09.U04 Lsc Supplemental Disaster $320,751
21.027 Coronavirus State and Local Fiscal Recovery Funds $317,490
21.008 Low Income Taxpayer Clinics $101,409
09.U02 Pro Bono Innovation Fund $94,938
09.U03 Tech Improvement Grant $35,000
16.524 Legal Assistance for Victims $13,771
64.033 Va Supportive Services for Veteran Families Program $6,764