Finding 1218244 (2025-001)

Material Weakness Repeat Finding
Requirement
BHIP
Questioned Costs
-
Year
2025
Accepted
2026-06-23

AI Summary

  • Core Issue: There are significant weaknesses in internal controls over financial transactions and reporting at PUR, leading to potential misstatements and risks of fraud.
  • Impacted Requirements: Compliance with COSO Framework, 2 CFR 200, and Oregon Revised Statute 65.771 is lacking, particularly in cash handling, disbursement approvals, and procurement documentation.
  • Recommended Follow-Up: PUR should enhance internal controls, ensure Board oversight, and document processes to address identified weaknesses and prevent future issues.

Finding Text

Finding 2025-001: Material Weaknesses in Internal Control Criteria: As a best practice, Partnership for the Umpqua Rivers, Inc. (PUR) should design, implement, and monitor internal control over financial transactions and reporting. Such controls should be based on guidance issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) Framework, as modified to suit the needs, size, and structure of PUR. In addition, 2 CFR 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, requires non-federal entities receiving federal awards to maintain internal controls. Finally, Oregon Revised Statute 65.771 requires Oregon corporations to maintain appropriate accounting records, which has been interpreted by the Oregon Department of Justice to include implementation of meaningful financial controls. Condition and Context: During the audit, we noted several deficiencies in internal control, sufficiently pervasive to call it a material weakness in internal control over financial transactions and reporting. We specifically noted the following deficiencies across our audit procedures: Cash receipts: There was no supervision or other oversight over cash receipts, such as a review of cash receipts to the bank deposits or a review of the monthly bank reconciliation. Cash disbursements: We noted not all general or project disbursements were approved, such as initials indicating approval or a signed purchase order. We also noted some support for disbursements was missing. However, we did find evidence of approval of timesheets throughout the year, email or other communication from project managers indicating authorization for disbursement, and signature of the Executive Director on all checks, thereby indicating tacit authorization for disbursement. Controls over cutoff: We noted in our testing that reimbursements requested for projects were not issued at the end of a period, but were issued as large expenses were presented. Board oversight of financial activity, internal control, and fraud and general risk assessment: We noted the Board of Directors does not take an active role in the oversight of the Organization’s financial operations, including monitoring internal control and performing regular assessments of fraud and general risks to financial operations. Oversight of procurement process: We noted sufficient documentation was not retained to support compliance with the procurement, suspension, and debarment requirements of federal awards. Effective internal control over the procurement process were not designed or implemented sufficient to prevent, or detect and correct, material noncompliance with this federal and state award requirement. Financial statement close: The unadjusted trial balance provided by management at the beginning of the audit contained unreconciled accounts, primarily a result of unreconciled prior year audit adjustments, which created inaccurate amounts on the unadjusted statements of financial position and activities. Questioned Costs: None noted. Cause: Ineffective design and implementation of internal control over financial activities and compliance with federal and state requirements. Effect or Potential Effect: A weak internal control framework enables the potential for misstatements to remain undetected and uncorrected. Such misstatements may be the result of error or fraud, including misappropriation of assets and fraudulent financial reporting. Repeat Finding: Repeat of findings 2024-001 through 2024-004. Recommendations: The Organization should continue to design and implement internal control that is effective for the Organization and its structure. The Organization should document internal control, including controls that mitigate inherent weaknesses in typical internal control measures. Such controls should also include oversight by the Board of Directors. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plan.

Corrective Action Plan

Finding 2025-001: Material Weaknesses in Internal Control Management’s response: Concur Responsible individual: Finance Manager, Executive Director, Board of Directors Anticipated completion date: March 31, 2026 Management agrees with this finding and will implement the following: • Develop and implement a formal document retention and destruction policy • Develop and implement a formal periodic close and invoicing policy • Develop and implement a formal conflict of interest policy • Develop and implement a formal internal control policy • Develop and implement a formal whistleblower policy • Develop and implement a formal Board code of ethics policy • Develop and implement a formal reporting schedule • Actively recruit Directors with financial experience to participate in Board oversight

Categories

Procurement, Suspension & Debarment Subrecipient Monitoring

Other Findings in this Audit

  • 1218217 2025-001
    Material Weakness Repeat
  • 1218218 2025-002
    Material Weakness Repeat
  • 1218219 2025-003
    Material Weakness Repeat
  • 1218220 2025-001
    Material Weakness Repeat
  • 1218221 2025-002
    Material Weakness Repeat
  • 1218222 2025-003
    Material Weakness Repeat
  • 1218223 2025-001
    Material Weakness Repeat
  • 1218224 2025-002
    Material Weakness Repeat
  • 1218225 2025-003
    Material Weakness Repeat
  • 1218226 2025-001
    Material Weakness Repeat
  • 1218227 2025-002
    Material Weakness Repeat
  • 1218228 2025-003
    Material Weakness Repeat
  • 1218229 2025-001
    Material Weakness Repeat
  • 1218230 2025-002
    Material Weakness Repeat
  • 1218231 2025-003
    Material Weakness Repeat
  • 1218232 2025-001
    Material Weakness Repeat
  • 1218233 2025-002
    Material Weakness Repeat
  • 1218234 2025-003
    Material Weakness Repeat
  • 1218235 2025-001
    Material Weakness Repeat
  • 1218236 2025-002
    Material Weakness Repeat
  • 1218237 2025-003
    Material Weakness Repeat
  • 1218238 2025-001
    Material Weakness Repeat
  • 1218239 2025-002
    Material Weakness Repeat
  • 1218240 2025-003
    Material Weakness Repeat
  • 1218241 2025-001
    Material Weakness Repeat
  • 1218242 2025-002
    Material Weakness Repeat
  • 1218243 2025-003
    Material Weakness Repeat
  • 1218245 2025-002
    Material Weakness Repeat
  • 1218246 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
10.665 SCHOOLS AND ROADS - GRANTS TO STATES $11,427
15.015 GOOD NEIGHBOR AUTHORITY $6,654
11.438 PACIFIC SALMON TREATY PROGRAM $2,755
66.460 NONPOINT SOURCE IMPLEMENTATION GRANTS $2,464
15.234 SECURE RURAL SCHOOLS AND COMMUNITY SELF-DETERMINATION $850
15.244 AQUATICS RESOURCES MANAGEMENT $63