Finding Text
Finding 2021-008 Noncompliance with Activities Allowed or Unallowed and Allowable Costs/Cost Principles and Period of Performance Finding 2021-009 Noncompliance with Eligibility Compliance Requirements: • Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Per 2 CFR 200.303, the auditee must establish and maintain effective internal control over federal awards and per 2 CFR 200.403, costs must be necessary, reasonable, allocable, and authorized consistent with policies and procedures that apply uniformly to both federally financed and other activities. The costs must also occur during the proper grant period of performance. • Eligibility – Per 2 CFR 200.303 and 2 CFR 200.331, the auditee must establish and maintain internal controls to ensure that only eligible individuals, organizations, or activities receive assistance under federal awards. Criteria: An effective system of internal control over compliance requires that expenditures charged to federal awards be supported by adequate documentation to demonstrate that: • Costs are necessary, reasonable, allocable, and allowable under program requirements. • Expenditures are for activities permitted under the terms and conditions of the award and recorded properly. • Participants or beneficiaries meet eligibility requirements. Condition: During our testing of expenditures and program activity for the federal program, we identified multiple instances in which transactions lacked adequate supporting documentation to demonstrate compliance with the above requirements. Specifically: • SSVF – ALN 64.033: Of the sixty expense transactions tested over SSVF, four did not have corresponding support or documentation to verify they were allowable activities, allowable costs, and recognized in the correct period. Specifically, invoices, purchase orders, or timesheets were missing, incomplete, or did not adequately substantiate the expenditures charged to the federal award. During testing of SSVF participant files, we noted that 13 out of 60 client files could not be located or were missing required documentation within their file, which did not allow us to properly determine if these participants were in fact eligible to be served under this program. Cause: The lack of documentation was primarily due to inadequate internal control procedures over record retention and verification. Additionally, there was significant turnover which contributed to inconsistent documentation practices. Effect or Potential Effect: Without sufficient supporting documentation, the Organization cannot demonstrate that: • Expenditures were for allowable activities. • Costs charged were necessary, reasonable, and allocable and recorded properly. • Participants or beneficiaries met eligibility requirements. Questioned costs: Due to insufficient documentation, the amount of questioned costs could not be determined. Recommendation: We recommend the Organization strengthen its compliance-related internal controls by: • Requiring standardized documentation to support compliance with each requirement. • Implementing periodic reviews of documentation completeness before charging costs to federal awards. • Providing training to staff responsible for grant management on compliance and record retention requirements. • Retain all documentation related to federal awards in a central location. Views of responsible officials: Management agrees with the finding and the recommendation. Corrective action plan: See Management’s Corrective Action Plan (Unaudited).