Finding Text
Finding 2025-005 – Revenue Recognition Cutoff and Schedule of Expenditures of Federal Awards – Material Weakness in Internal Control Over Compliance and Noncompliance (Repeat Finding – Prior Year 2024-002) Criteria or Specific Requirement: The Uniform Guidance, 2 CFR 200.510(b), requires the auditee to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the financial statements, which must include the total federal awards expended as determined in accordance with 2 CFR 200.502. Additionally, 2 CFR 200.403 requires that costs charged to federal awards be allocable, allowable, and properly recorded in the period in which they are incurred. 27 Condition: During the audit of the fiscal year ended June 30, 2025, it was determined that revenue earned under the Indian Health Service Behavioral Health Programs grant (CFDA 93.654, Award No. BH22IHS0008) during the fiscal year ended June 30, 2024 was not recognized until the fiscal year ended June 30, 2025. The misapplication of the revenue recognition cutoff resulted in federal award revenue and expenditures being reported on the SEFA in the incorrect fiscal year, requiring a material post-close adjusting journal entry. This finding is a repeat of prior year Finding 2024-002. Cause and Effect: Controls over the period-end review of federal award revenue recognition and SEFA preparation were not operating effectively. The Organization did not perform a sufficient review of grant expenditure activity and award eligibility requirements relative to the June 30 fiscal year-end cutoff. The recurrence of this condition, despite being identified and reported in the prior year audit, indicates that corrective actions implemented were not sufficient to prevent the issue from recurring. Auditors' Recommendations: Management should implement a formal SEFA preparation and review process to ensure federal award expenditures are accurately reported for each fiscal year. A designated Finance staff member with sufficient knowledge of the Uniform Guidance requirements should be responsible for overseeing SEFA preparation for each fiscal year-end. A grant-by-grant SEFA reconciliation should be completed prior to year-end close. Management should engage its external accountants earlier in the year-end close process to allow sufficient time to identify and correct any SEFA discrepancies prior to fieldwork. Management's Response: Management has implemented a series of 3 checks and balance procedures for monthly review for SEFA procedures. A finance staff member with Uniform Guidance requirements will prepare the annual statement preparation at year end with review from Director of Finance and Board Treasurer before submission.