Finding 1186675 (2025-001)

Material Weakness Repeat Finding
Requirement
C
Questioned Costs
-
Year
2025
Accepted
2026-03-25

AI Summary

  • Core Issue: Lack of documented review and approval for drawdown reimbursement requests increases risk of unallowable costs.
  • Impacted Requirements: Compliance with Uniform Guidance (2 CFR Part 200) on internal controls and documentation for Federal awards.
  • Recommended Follow-Up: Formalize and consistently apply procedures for documented reviews and retain records as required.

Finding Text

Finding 2025-001: Cash Management Federal Program: Building an Inclusive Workforce: Lifting Underrepresented Communities Assistance Listing Number: 17.289 Federal Agency: U.S. Department of Labor Federal Award Number(s): 24A60CP000157-01-04 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: Uniform Guidance (2 CFR Part 200) requires non-Federal entities to establish and maintain effective internal controls over Federal awards that provide reasonable assurance that transactions are properly recorded, processed, and reported, and that compliance with Federal statutes, regulations, and the terms and conditions of the Federal award is achieved. This includes maintaining documentation evidencing the review and approval of drawdown reimbursement requests to ensure that only allowable costs are charged to the Federal program. Condition: During our audit, we noted that although the Coalition was able to provide general ledger detail supporting the amounts drawn down, there was no documentation evidencing review and approval of drawdown reimbursement requests prior to submission. Accordingly, we were unable to determine whether an independent review was performed to verify the accuracy and allowability of the amounts requested. Cause: This condition resulted from a transition in the controller position during the audit period, during which established procedures for documenting review and approval of drawdown reimbursement requests were not consistently followed. Effect or Potential Effect: The absence of documented review and approval increases the risk that unallowable or unsupported costs could be charged to the Federal program and that errors may not be identified and corrected in a timely manner. Questioned Costs: None. Context: 2 of 2 samples lacked documentation evidencing review and approval prior to submission. The sample is representative of the population. Identification as a Repeat Finding, if Applicable: Not applicable. Recommendation: We recommend that the Coalition formalize and consistently apply procedures requiring documented review and approval of all drawdown reimbursement requests prior to submission, and that such documentation be retained in accordance with Uniform Guidance record retention requirements.

Corrective Action Plan

Views of Responsible Official: Management notes that the Federal Payment Management System (PMS) automatically tracks when different users enter information such as submitting and certifying/approving draw-down amounts. During the time of the grant there were periods when only one staff member had access to PMS due to technical issues and delays in adding new users. To ensure there is back-up documentation of the approval workflow, we will institute a form to capture the individual signatures of the preparer and submitter of each draw down as additional evidence of multiple people connected to the process.

Categories

Allowable Costs / Cost Principles Cash Management

Other Findings in this Audit

  • 1186676 2025-002
    Material Weakness Repeat
  • 1186677 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
17.289 COMMUNITY PROJECT FUNDING/CONGRESSIONALLY DIRECTED SPENDING $664,849
93.110 MATERNAL AND CHILD HEALTH FEDERAL CONSOLIDATED PROGRAMS $243,308
93.800 ORGANIZED APPROACHES TO INCREASE COLORECTAL CANCER SCREENING $46,165
93.898 CANCER PREVENTION AND CONTROL PROGRAMS FOR STATE, TERRITORIAL AND TRIBAL ORGANIZATIONS $19,247