Finding 1201506 (2025-002)

Material Weakness Repeat Finding
Requirement
AB
Questioned Costs
-
Year
2025
Accepted
2026-03-30

AI Summary

  • Core Issue: Internal controls over compliance are inadequate, leading to costs not being recorded in the correct fiscal year.
  • Impacted Requirements: Non-compliance with GAAP and Uniform Guidance, risking material misstatements in federal award reporting.
  • Recommended Follow-Up: Implement stronger policies to ensure costs are accrued in the correct period, enhancing accuracy in federal expenditure reporting.

Finding Text

2025-002 – Activities Allowed or Unallowed, Allowable Costs/Cost Principles – Significant Deficiency in Internal Control over Compliance and Noncompliance Federal Agencies: Department of Agriculture Federal Assistance Listing Numbers: 10.182 Programs: Pandemic Relief Activities: Local Food Purchase Agreements with States, Tribes, and Local Governments Award/Pass-Through Entity Identifying Numbers: F4303 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with federal statues, regulations, and the terms and conditions of the federal award. Per 2 CFR §200.403(e), costs must be in accordance with Generally Accepted Accounting Procedures (GAAP) to be allowable under federal awards. Condition: During the testing of non-payroll related costs for the year ended June 30, 2025, two of 20 transactions selected for testing within the program were incurred in the year ended June 30, 2024. This practice is not in accordance with GAAP, which requires that costs be recorded in the period in which they are incurred. Both transactions were incurred and reported within the grant’s period of performance. Cause: The Organization did not have adequate policies and procedures in place to ensure that federal expenditures are properly accrued and recorded in the fiscal year in which the costs are actually incurred. Effect or Potential Effect: Failure to accrue costs in accordance with GAAP may result in expenditures being materially misstated on the schedule of expenditures of federal awards that could lead to inaccurate reporting to the federal agencies. Questioned Costs: Known Questioned Costs: $5,095 Likely Questioned Costs: $31,125 Context: This is a condition identified per review of the Organization’s compliance with specified requirements not using a statistically valid sample. Known questioned costs are $5,095 out of the total non-payroll related costs during the year ended June 30, 2025, which were $443,033. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend the Organization implement policies and procedures to accrue for federal expenditures in the period the costs were incurred to ensure costs are being recorded in accordance with GAAP and the schedule of expenditures of federal awards is representative of all federal expenditures incurred in the reporting year. Views of Responsible Officials: Management agrees with the finding. Management is formalizing and enhancing policies and procedures over cutoff and accruals.

Corrective Action Plan

2025-002 Accounts Payable Cutoff We acknowledge BDO’s inquiry regarding an invoice that appeared to relate to the prior fiscal period. The invoice was received after Accounts Payable closed without advance notification for accrual. BDO noted a similar issue in an additional sample. To strengthen our accounts payable cutoff controls and prevent similar issues, we will implement the following improvement measures: • Formalize the Accrual Process – While an accrual process already exists, before the end of FY26, we will document and strengthen the accrual procedures by requiring Program Managers to notify Finance, specifically the AP team inbox, when work from a vendor has been completed, but an invoice has not yet been received, on an annual basis by a given deadline. This will ensure that known obligations are captured in the correct fiscal period. • Strengthen Review of Post-Year-End Invoices – While regular review of invoices is already a part of our regular AP process, Accounts Payable will implement a more stringent review process before the end of FY26 for all invoices received in the first period after fiscal year end, including verification of service dates, contract terms, and deliverables. • Enhanced Communication Expectations – Program Managers will receive training and guidance before the end of FY26 on the importance of timely invoice submission and the need to alert Finance when delays occur. • Documentation of Cutoff Decisions – For invoices received after close, before the end of FY26, Accounts Payable will document the receipt date, supporting details, and rationale for the period in which the expense is recorded to maintain a clear audit trail. These improvements will strengthen our internal controls over AP cutoff, improve the consistency of accrual practices, and reduce the risk of misstatements due to late or ambiguous invoices. Responsible Individual: Claire Danielson, VIP of Finance Estimated Completion Date: June 30, 2026

Categories

Reporting Allowable Costs / Cost Principles

Other Findings in this Audit

  • 1201505 2025-002
    Material Weakness Repeat
  • 1201507 2025-003
    Material Weakness Repeat
  • 1201508 2025-003
    Material Weakness Repeat
  • 1201509 2025-004
    Material Weakness Repeat
  • 1201510 2025-004
    Material Weakness Repeat
  • 1201511 2025-004
    Material Weakness Repeat
  • 1201512 2025-004
    Material Weakness Repeat
  • 1201513 2025-005
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
10.569 EMERGENCY FOOD ASSISTANCE PROGRAM (FOOD COMMODITIES) $4.43M
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $3.92M
14.251 ECONOMIC DEVELOPMENT INITIATIVE, COMMUNITY PROJECT FUNDING, AND MISCELLANEOUS GRANTS $1.16M
14.239 COVID-19 HOME INVESTMENT PARTNERSHIPS PROGRAM $455,000
10.182 PANDEMIC RELIEF ACTIVITIES: LOCAL FOOD PURCHASE AGREEMENTS WITH STATES, TRIBES, AND LOCAL GOVERNMENTS $368,342
14.239 HOME INVESTMENT PARTNERSHIPS PROGRAM $352,808
93.959 COVID-19 BLOCK GRANTS FOR PREVENTION AND TREATMENT OF SUBSTANCE ABUSE $238,026
93.566 REFUGEE AND ENTRANT ASSISTANCE STATE/REPLACEMENT DESIGNEE ADMINISTERED PROGRAMS $188,831
21.027 COVID-19 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $158,863
10.568 EMERGENCY FOOD ASSISTANCE PROGRAM (ADMINISTRATIVE COSTS) $153,413
93.268 IMMUNIZATION COOPERATIVE AGREEMENTS $130,381
10.561 STATE ADMINISTRATIVE MATCHING GRANTS FOR THE SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM $124,804
93.959 BLOCK GRANTS FOR PREVENTION AND TREATMENT OF SUBSTANCE ABUSE $116,325
10.187 THE EMERGENCY FOOD ASSISTANCE PROGRAM (TEFAP) COMMODITY CREDIT CORPORATION ELIGIBLE RECIPIENT FUNDS $107,096
10.558 CHILD AND ADULT CARE FOOD PROGRAM $99,085
10.182 COVID-19 PANDEMIC RELIEF ACTIVITIES: LOCAL FOOD PURCHASE AGREEMENTS WITH STATES, TRIBES, AND LOCAL GOVERNMENTS $85,958
93.958 BLOCK GRANTS FOR COMMUNITY MENTAL HEALTH SERVICES $79,855
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $49,219
93.575 CHILD CARE AND DEVELOPMENT BLOCK GRANT $23,551
97.024 EMERGENCY FOOD AND SHELTER NATIONAL BOARD PROGRAM $14,000
93.597 GRANTS TO STATES FOR ACCESS AND VISITATION PROGRAMS $11,830
93.493 CONGRESSIONAL DIRECTIVES $4,096