Finding 1179529 (2024-005)

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

AI Summary

  • Core Issue: The Organization failed to maintain separate accounting records for federal grant expenditures, mixing them with other expenses.
  • Impacted Requirements: This violates 2 CFR 200.302, which mandates accurate tracking and reporting of federal funds.
  • Recommended Follow-Up: Implement a dedicated accounting system to track federal expenditures separately, ensuring compliance and accurate reporting.

Finding Text

ALN 21.027 Finding #2024‐005 Insufficient Accounting to Track Federal Grant Expenditures Repeat Finding: No Condition: The Organization did not maintain accounting records that sufficiently tracked expenditures relating to the federal program. Instead, federal program expenditures were co‐mingled with all other organizational expenditures. As a result, the Organization was unable to readily identify the federal share of costs or demonstrate that the costs charged were allowable under the terms of the award. Criteria: Per 2 CFR 200.302, non‐federal entities must maintain financial management systems that provide for: · Accurate, current, and complete disclosure of financial results of each federal award; · Records that identify adequately the source and application of federal funds; and · Effective control and accountability for all funds, property, and other assets. These requirements include maintaining accounting records that segregate federal program expenditures from non‐federal activity to ensure compliance with applicable statutes, regulations, and terms of the award. Cause: The Organization did not implement accounting controls and procedures to establish separate accounts or cost centers for federal program expenditures. Effect: Because federal program expenditures were not separately tracked, there is an increased risk of: · Unallowable or unsupported costs being charged to the program, · Inaccurate reporting on the Schedule of Expenditures of Federal Awards (SEFA), and · Noncompliance with Uniform Guidance financial management standards. Questioned Costs: None noted. Perspective Information: The condition affected one of the Coronavirus State and Fiscal Recovery – ARPA grants, ALN 21.027, which accounted for $153,653 of federal expenditures for 2024. Recommendation: We recommend that the Organization implement an accounting system that separately tracks federal program expenditures, either through distinct general ledger accounts, cost centers, or project codes. The system should allow management to readily identify federal expenditures, prepare accurate SEFA reporting, and demonstrate compliance with federal requirements. Reporting Views of Responsible Officials: The Organization agrees with the finding. The Organization is in process of implementing a project‐based ledger and procedures to ensure federal expenditures are properly coded so they are readily identifiable.

Corrective Action Plan

Finding Number: 2024-005 Finding Title: Insufficient Accounting to Track Federal Grant Expenditures Federal Program Information: • Federal Agency: Department of the Treasury • Assistance Listing Number (ALN): 21.027 • Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Compliance Requirement: Financial Management and Standards of Financial Management Systems (2 CFR §200.302) Questioned Costs: $0 Repeat Finding: No Management's Response: The Board of Directors of Restoration Christian Ministries agrees with the finding. The Organization is in process of implementing a project based ledger and procedures to ensure federal expenditures are properly coded so they are readily identifiable. Corrective Action Plan: Corrective Action #1: Project-Based Accounting System Implementation • Action: Implement project-based accounting system assigning unique project codes to each federal award. Configure general ledger to separately track revenues and expenditures by federal program. Establish cost centers or fund codes specific to federal programs. Board Treasurer will approve system modifications. • Responsible Person/Title: Contract Accountant and Board Treasurer • Anticipated Completion Date: March 31, 2026 Corrective Action #2: Chart of Accounts Restructuring • Action: Redesign chart of accounts to include distinct account codes for federal program expenditures. Create account code structure identifying: (a) funding source, (b) program/project, and (c) expense category. Document structure and provide to Board Treasurer. Board will formally approve revised chart of accounts. • Responsible Person/Title: Contract Accountant • Anticipated Completion Date: February 28, 2026 Corrective Action #3: Expense Coding Procedures • Action: Develop written procedures for charging costs to federal programs, including documentation requirements. Implement procedures for allocating shared costs where applicable. Require all federal program expenditures coded with appropriate project/grant identifiers at time of transaction entry. Board Treasurer will review and approve expense allocation methodology. • Responsible Person/Title: Contract Accountant • Anticipated Completion Date: March 31, 2026 Corrective Action #4: Training and Implementation Support • Action: Provide training to Contract Accountant on new account structure and federal award tracking requirements. Ensure Contract Accountant has access to technical resources and support. Consider engaging consultant to assist with initial implementation. • Responsible Person/Title: Board Treasurer • Anticipated Completion Date: April 30, 2026 Corrective Action #5: Monthly Reconciliation and Monitoring • Action: Contract Accountant will perform monthly reconciliations of federal program expenditures by grant. Generate monthly expenditure reports by federal award for Board Treasurer review. Compare recorded expenditures to grant budgets and terms to identify irregularities. Board Treasurer will report federal grant expenditure status to full Board monthly. • Responsible Person/Title: Contract Accountant and Board Treasurer • Anticipated Completion Date: April 30, 2026 (initial); Ongoing monthly thereafter

Categories

Reporting Allowable Costs / Cost Principles

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
  • 1179528 2024-004
    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