Finding 1171328 (2023-005)

Material Weakness Repeat Finding
Requirement
CG
Questioned Costs
-
Year
2023
Accepted
2026-01-30
Audit: 384599
Organization: Healing Action Network Inc (MO)
Auditor: UHY LLP

AI Summary

  • Core Issue: Inadequate internal controls over financial management for federal awards, leading to discrepancies in cash drawdowns and reporting.
  • Impacted Requirements: Non-compliance with 2 CFR §200.302 regarding record-keeping and reconciliation of federal funds.
  • Recommended Follow-Up: Implement formal review and approval processes, ensure consistent reconciliations, and conduct regular internal audits and staff training.

Finding Text

Criteria: The Services and Transitional Housing for Trafficking Victims program requires that financial management procedures are followed for all federal awards in accordance with 2 CFR §200.302. Maintaining records that sufficiently identify the amount, source, and expenditure offederal funds for Federal awards. These records must contain information necessary to identifyfederal awards, authorizations, financial obligations, unobligated balances, as well as assets,expenditures, income, and interest. All records must be supported by source documentation. Condition: During the audit, it was noted that cash drawdowns, reimbursements, invoicing, and matching requirement reporting were performed without reconciliations to the general ledger consistently and lacked formal review and approval. Errors were identified in total expenses per the general ledger that did not agree to submitted reimbursement requests, and expenditure reporting could not be reconciled to the general ledger due to differences in reporting periods and incomplete supporting documentation. These observations demonstrate a lack of adequate internal controls over the recording, review, and approval of federal award transactions. Cause: The condition resulted from the accounting practices of the previously retained outsourced accounting firm in which internal controls over drawdowns, reimbursements, invoicing, SEFA reporting, and matching contributions were not formally established or enforced. Specifically, review, approval, and reconciliation procedures were not consistently followed, leading to errors and incomplete details. Additionally, management did not properly oversee the services to ensure these processes were properly being followed. Questioned Cost: $-0- Effect:Thelack offormalreview,approval,andreconciliation controls increasestheriskofinaccurate reportingoffederalexpenditures and matchingcontributions.The conditionrepresents a reportable deficiency thatcould resultin errors,misstatements,or noncompliancewith federalrequirements. Recommendation:Werecommendmanagementmaintain and enforceformalreviews, approvals,andreconciliation proceduresforalldrawdowns,reimbursements,invoicing,federalfinancialreporting,andmatchingcontributions.Managementshould ensure thatalltransactionsare consistently reconciledto thegeneralledger,adequately documented,and approvedpriortosubmission.Continuedmonitoring,periodic internalaudits,and stafftrainingshould beimplementedtopreventrecurrenceofdeficiencies. Classification:Compliancefindingandsignificantdeficiency in internalcontrols

Corrective Action Plan

View ofResponsible Officials and Planned CorrectiveActions:Managementacknowledges this findingrelated to federalaward financialmanagementduringfiscalyear 2023.Drawdownswere previouslymanaged by theorganization’s externalaccounting firm,and internalreviewbystaffnolongerwith theorganization was notsufficiently consistent.These issues were a keyfactorin management’sdecisionto endtherelationship with theprioraccounting firm. We transitioned all drawdown and reimbursement responsibilities internally. We required management review and initialing of all drawdowns prior to submission. We implemented standardized reconciliation processes tying drawdowns to the general ledger by reporting period. We retained all drawdown support directly within QuickBooks to document how totals were calculated. We developed grant-specific allocation roadmaps. We established a centralized grant file system for all federal financial documentation. We engaged a new accounting firm for compliance support and oversight. All drawdowns and reimbursements are reviewed and approved by the Executive Director prior to submission, with ongoing oversight from the accounting firm. Corrective actions have been implemented and are operating on an ongoing basis.

Categories

Reporting Cash Management

Other Findings in this Audit

  • 1171325 2023-002
    Material Weakness Repeat
  • 1171326 2023-003
    Material Weakness Repeat
  • 1171327 2023-004
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
16.575 CRIME VICTIM ASSISTANCE $199,533
16.320 SERVICES FOR TRAFFICKING VICTIMS $179,265
94.006 AMERICORPS STATE AND NATIONAL 94.006 (Covid-19) $47,411
94.006 AMERICORPS STATE AND NATIONAL 94.006 $38,417