Finding Text
Criteria:2 CFR §200.303(a) requires non-federal entities to establish and maintain effective internal control over federal awards that provides reasonable assurance that the entity is managing federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Effective internal control should be consistent with the COSO Internal Control—Integrated Framework or the GAO Green Book. In addition, Uniform Guidance requires written policies and procedures in certain compliance areas. Condition:The entity does not have a formally documented system of internal control, including written policies and procedures, over its federal programs. While certain controls are performed in practice, these controls are not formally documented Cause:Management has not developed or formally documented written policies and procedures related to internal control over compliance with federal requirements. Effect / Potential Effect: The absence of written policies and procedures increases the risk that controls may not be consistently applied, that staff may not have clear guidance regarding compliance responsibilities, and that noncompliance with federal requirements could occur and not be detected or prevented in a timely manner. No instances of noncompliance were identified during audit testing. Questioned Costs:None. Repeat Finding:No. Recommendation:We recommend that management develop, implement, and maintain written policies and procedures documenting its system of internal control over federal programs to ensure compliance with Uniform Guidance and applicable federal requirements. Views of Responsible Officials and Planned Corrective Action:Management agrees with the finding and plans to develop and implement written internal control policies and procedures over federal programs. Management anticipates completion by June 30, 2026.