Finding 1168084 (2024-004)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
-
Year
2024
Accepted
2026-01-07

AI Summary

  • Core Issue: The Organization failed to keep necessary documentation for reports submitted to the National Science Foundation, leading to noncompliance with federal reporting requirements.
  • Impacted Requirements: Compliance with 2 CFR 200.301, 200.328, and 200.512(a) regarding documentation retention and timely submission of audit packages.
  • Recommended Follow-Up: Implement stronger policies and procedures to ensure proper record-keeping and timely filing of reports in the future.

Finding Text

2024-004 – Reporting Program: ALN# 47.070 = Computer and Information Science and Engineering Grant #: 2216614, 2122756, Grant Period: Year Ended December 31, 2024 Government Agency: National Science Foundation Criteria: Under 2 CFR 200.301 and 2 CFR 200.328, non-Federal entities must maintain documentation sufficient to demonstrate compliance with Federal reporting requirements, including performance and financial reporting. Per the requirements contained in 2 CFR 200.512 (a), the auditee is responsible for submitting the data collection form and the reporting package, including the auditors’ reports, within the earlier of 30 days after receipt of the auditors’ report or nine months after the end of the audit period to the federal audit clearinghouse. Condition: The Organization was unable to provide supporting documentation for the reports submitted to the Federal agency. Specifically, the Organization did not retain copies of the financial and performance reports, nor did it maintain documentation evidencing the data used to prepare those reports. The audit package and data collection form were not submitted to the Federal Audit Clearinghouse for the reporting year December 31, 2024 within nine months after the end of the audit period. Cause: The Organization’s document retention procedures are not sufficiently designed or implemented to ensure that required reporting documentation is retained in accordance with the Uniform Guidance. Account analyses were not performed in a timely manner throughout the year and this led to delays in the start of the audit process. Effect: The lack of adequate documentation increases the risk that: • Reports submitted to the funding agency may be inaccurate or incomplete. • Reporting errors may go undetected. • The Organization may be found noncompliance with Federal record retention requirements. The Organization is deficient in its submission of the required audit reporting package and data collection form. As such, the Organization is noncompliant with the reporting requirements. Questioned Costs: No questioned costs identified. Context: This sample was not intended to be, and was not, a statistically valid sample. Repeat Finding: Yes Recommendation: We recommend that the Organization implement appropriate policies, procedures and controls to ensure that records are maintained in accordance with the applicable compliance requirements and to ensure that future submissions of the Uniform Guidance reports are filed timely. Views of Responsible Officials: See management corrective action plan attached.

Corrective Action Plan

Response to finding 2024-004 – Reporting Views of Responsible Officials: CSforALL management agrees with the conditions identified by SAX Advisory Group, including the noted causes and resulting effects under 2024-004. During the audit period, recordkeeping was not centrally maintained, and key documents were often stored under individual employee drives rather than within a shared, organization-controlled system. Due to the organizational pause at the end of 2024 and the transition period throughout 2025, the Organization had limited capacity to implement formal reporting controls; however, foundational corrective steps were initiated in 2025 to support full compliance during the 2026 operating year. This finding continued into the 2024 audit period due to the decentralized recordkeeping practices described above. Corrective Action taken in 2025: The Operations Manager conducted a full triage of existing accounts and transferred organizational documents into centralized CSforALL Drives. Files were reorganized by year and subject matter to ensure accessibility, consistency, and proper retention. This restructured system now provides a unified location for all grant-related documents, reporting records, and compliance materials, establishing a baseline for future Uniform Guidance reporting requirements. Corrective Action Planned for 2026: Beginning in 2026, CSforALL will implement formalized policies and procedures to ensure records are maintained in accordance with applicable compliance requirements and that all Uniform Guidance reports are submitted timely. The Operations Manager and Accounting team will oversee ongoing documentation, retention, and periodic internal review to ensure the reporting structure remains organized, accessible, and compliant throughout the 2026 operating year and beyond.

Categories

Reporting Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 1168082 2024-002
    Material Weakness Repeat
  • 1168083 2024-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
47.070 COMPUTER AND INFORMATION SCIENCE AND ENGINEERING $1.62M
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $110,362