Finding Text
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.329, recipients must submit performance reports as required by the Federal awarding agency and ensure such reports are accurate, complete, and submitted timely. Additionally, 2 CFR 200.303 requires the entity to establish and maintain effective internal controls over Federal awards, including controls that provide reasonable assurance that reporting requirements are met and that documentation is retained to support compliance. Condition: During testing of reporting, we noted the following: - Management stated that required reviews and approvals of performance reports were conducted in person, but the organization does not maintain documentation or an audit trail to evidence these reviews. While documentation was available for quarterly performance reports, 2 of 2 annual performance reports and 6 of 21 monthly performance reports tested lacked evidence of review and approval. - Additionally, 6 of 10 performance reports selected for testing were not submitted/uploaded timely in accordance with grantor requirements. Questioned costs: None Context: A control system to prevent and detect errors in the reporting process was not created at the time the reports were filed. Cause: The Organization has not established formalized policies and procedures governing the preparation, review, and timely submission of performance reports. As a result, responsibility for monitoring reporting deadlines and performing supervisory review was informal and not consistently documented. Effect: Failure to submit required performance reports timely increases the risk of noncompliance with federal award requirements and may result in adverse actions by the federal awarding agency, including delayed reimbursements or additional monitoring. Additionally, the lack of a documented review process increases the risk that performance reports may be incomplete, inaccurate, or not aligned with program requirements. Repeat finding: No Recommendation: We recommend the Organization develop and implement formal policies and procedures to ensure required performance reports are prepared, reviewed, and submitted in a timely manner. Such procedures should include clearly defined roles and responsibilities, tracking of reporting deadlines, and documented evidence of supervisory review and approval prior to submission. Views of responsible officials: There is no disagreement with the audit finding.