Finding 1179528 (2024-004)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
-
Year
2024
Accepted
2026-03-16

AI Summary

  • Core Issue: The Organization incorrectly recorded $2,425,133 in federal expenditures as expenses instead of as a note receivable, leading to financial misstatements.
  • Impacted Requirements: This misclassification violates 2 CFR 200.302 and GAAP, which require accurate financial reporting and proper classification of federal funds.
  • Recommended Follow-Up: Strengthen internal controls and review processes to ensure disbursements are correctly classified as expenses or loans/note receivables in line with federal and GAAP standards.

Finding Text

ALN 14.251 and ALN 21.027 Finding #2024‐004 Incorrect Recording of Expenditures that were Notes Receivable Draws Repeat Finding: No Condition: The Organization recorded $2,425,133 of federal program expenditures as expenses in the year ended December 31, 2024. These amounts represented disbursements made to a subrecipient under terms that required repayment, and therefore should have been recorded as a note receivable. The Organization did not recognize the note receivable nor properly classify the related transactions, resulting in a misstatement of expenditures and assets. Criteria: In accordance with 2 CFR 200.302 and generally accepted accounting principles (GAAP), the Organization is required to maintain accurate, current, and complete disclosure of financial results of each federal award. Accounting records must adequately identify the source and application of federal funds and properly classify transactions, assets, liabilities, and equity in accordance with GAAP. Cause: The misclassification occurred because the Organization did not have sufficient internal controls to ensure that disbursements under this program were evaluated for the proper accounting treatment (i.e., expense versus note receivable/loan). Effect: Federal program expenditures were overstated by $2,245,133 and assets were understated by the same amount. The lack of proper classification may affect stakeholders’ understanding of the Organization’s financial position and federal compliance. Questioned Costs: None noted, as the expenditures were incurred under the program; however, the classification error represents a material reporting misstatement. Perspective Information: The condition noted represents $2,425,133 of expenditures, which were inaccurately reported. Recommendation: We recommend that the Organization strengthen its review process over accounting for federal program disbursements. Policies and procedures should require evaluation of whether disbursements meet the definition of an expense or a loan/note receivable in accordance with GAAP and federal reporting requirements. Reporting Views of Responsible Officials: The Organization agrees with the finding. The Organization’s accountant was unaware that the federal grant payments to the subrecipient were considered draws on a note receivable. Corrections have been made to improve communication with the accountant to ensure the accountant is aware of key grant provisions and to ensure note receivable draws are being properly accounted for in the general ledger.

Corrective Action Plan

Finding Number: 2024-004 Finding Title: Incorrect Recording of Expenditures that were Notes Receivable Draws Federal Program Information: • Federal Agency: Department of Housing and Urban Development; Department of the Treasury • Assistance Listing Numbers (ALN): 14.251 and 21.027 • Federal Program Names: Economic Development Initiatives—Special Project, Neighborhood Initiative and Neighborhood Stabilization Program; Coronavirus State and Local Fiscal Recovery Funds Compliance Requirement: Financial Management and Standards of Financial Management Systems (2 CFR §200.302); GAAP Questioned Costs: $0 (classification error, not allowability issue) Repeat Finding: No Management's Response: The Board of Directors of Restoration Christian Ministries agrees with the finding. The Organization's accountant was unaware that the federal grant payments to the subrecipient were considered draws on a note receivable. Corrections have been made to improve communication with the accountant to ensure the accountant is aware of key grant provisions and to ensure note receivable draws are being properly accounted for in the general ledger. Corrective Action Plan: Corrective Action #1: Grant Communication Protocol • Action: Establish formal process requiring Board members to provide detailed grant term summaries to Contract Accountant for all new federal awards. Create standardized grant summary form identifying key provisions affecting accounting treatment, including repayment terms, loan features, and contingencies. Hold kick-off meetings between Board representatives and Contract Accountant for all awards exceeding $100,000. Board President will maintain grants management file accessible to Contract Accountant. • Responsible Person/Title: Board President and Contract Accountant • Anticipated Completion Date: January 31, 2026 Corrective Action #2: Transaction Classification Review Procedures • Action: Implement review procedures requiring evaluation of all federal program disbursements to determine proper classification (expense vs. loan/note receivable). Contract Accountant will develop decision tree guidance. Require Board Treasurer approval for all disbursements exceeding $50,000 with verification of proper classification. • Responsible Person/Title: Contract Accountant and Board Treasurer • Anticipated Completion Date: February 28, 2026 Corrective Action #3: Chart of Accounts Modification • Action: Create separate general ledger accounts for notes receivable related to federal programs. Establish clear account coding guidelines distinguishing between grant expenditures and note receivable advances. Board Treasurer will review and approve modifications. • Responsible Person/Title: Contract Accountant • Anticipated Completion Date: January 31, 2026 Corrective Action #4: Professional Development • Action: Ensure Contract Accountant receives training on identifying and accounting for various federal program transaction types, including loans, advances, and conditional grants. Consider engaging consultant with federal grants expertise for technical assistance. Provide Board members basic training on federal grant structures to improve communication with Contract Accountant. • Responsible Person/Title: Board Treasurer • Anticipated Completion Date: February 28, 2026 Corrective Action #5: Quarterly Account Review • Action: Conduct quarterly reviews of all federal program accounts to verify proper transaction classification. Reconcile notes receivable balances to underlying agreements and repayment schedules. Report findings to full Board quarterly. • Responsible Person/Title: Board Treasurer • Anticipated Completion Date: March 31, 2026 (initial); Ongoing quarterly thereafter

Categories

Subrecipient Monitoring Reporting Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Special Tests & Provisions

Other Findings in this Audit

  • 1179524 2024-002
    Material Weakness Repeat
  • 1179525 2024-003
    Material Weakness Repeat
  • 1179526 2024-003
    Material Weakness Repeat
  • 1179527 2024-004
    Material Weakness Repeat
  • 1179529 2024-005
    Material Weakness Repeat
  • 1179530 2024-006
    Material Weakness Repeat
  • 1179531 2024-006
    Material Weakness Repeat
  • 1179532 2024-007
    Material Weakness Repeat
  • 1179533 2024-007
    Material Weakness Repeat
  • 1179534 2024-008
    Material Weakness Repeat
  • 1179535 2024-009
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.251 ECONOMIC DEVELOPMENT INITIATIVE, COMMUNITY PROJECT FUNDING, AND MISCELLANEOUS GRANTS $1.53M
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $1.05M