Finding Text
Criteria: The A-102 Common Rule requires that non-Federal entities receiving federal awards establish and maintain internal control designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Adequate segregation of duties provided between performance, review, and recordkeeping of a task is a control activity which will reasonably ensure compliance with federal laws, regulations, and program requirements. Condition: Documentation of preparer and reviewer could not be readily substantiated for two reimbursement requests selected for testing which is part of the Organization’s controls over allowable costs/activities and cash management. Questioned Costs – None. Context: Review of reimbursement requests are not performed in a consistent manner or consistently documented. Various methods, including emails, Teams chats, and informal verbal communications, are used by the Organization. Evidence was provided for other reimbursement requests being reviewed and approved through various methods. However, for the reimbursement requests selected for testing, documentation of review and approval could not be readily substantiated. Effect: By not maintaining adequate and consistent documentation of review, the Organization may not be able to readily prevent, detect, and correct potential errors in allowable costs/activities and cash management requirements. Therefore, the Organization may be incorrectly reimbursed for expenditures under the program requirements. Cause: Current processes do not include a consistent method of performing, documenting, and maintaining adequate documentation of the review of reimbursement requests.