Finding 1222688 (2025-001)

Material Weakness Repeat Finding
Requirement
B
Questioned Costs
-
Year
2025
Accepted
2026-07-01
Audit: 406271
Organization: School's Out Washington (WA)
Auditor: CLARK NUBER PS

AI Summary

  • Core Issue: There is a significant deficiency in internal controls over compliance related to allowable costs for federal awards.
  • Impacted Requirements: Costs charged to the grant must be necessary and reasonable, as outlined in U.S. CFR 200.
  • Recommended Follow-Up: SOWA should improve communication of internal controls to staff and consider strengthening these controls to prevent unallowable costs.

Finding Text

Section III - Federal Award Findings and Questioned Costs Finding 2025-001 Significant deficiency in internal controls over compliance related to allowable costs. Federal Agency: Department of Health and Human Services Program Titles: Refugee and Entrant Assistance State/Replacement Designee Administered Programs Assistance Listing Number: 93.566 Award Number: 2134-30265 Award Period: October 1, 2021 - September 30, 2025 Criteria 2 U.S. Code of Federal Regulations (CFR) 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards provides for specific items of cost which are considered to be unallowable. Additionally, costs must be necessary and reasonable. SOWA’s internal controls over allowable costs failed to remove these items from allowable costs. Condition/Context During the testing of allowable costs, there were two instances where costs that were not necessary or reasonable were directly allocated to the grant. Questioned Costs $118 - Known Questioned Costs were computed based on the accumulation of the portion of transactions tested that were deemed not necessary and reasonable and were confirmed noncompliant. Cause SOWA’s operation of internal controls was not sufficient to ensure that unnecessary/reasonable costs charged to federal awards were not charged to the grant. Effect Based on the exception noted in the operation of internal controls, unallowable costs could be charged to the Federal Award. Repeat Finding This is not a repeat finding. Recommendation We recommend that SOWA ensures current internal controls are communicated to staff charging expenses to federal awards and consider the need for further strengthening internal controls over allowable costs. Views of Responsible Official of Auditee Management concurs with the finding and has provided accompanying corrective action plan.

Corrective Action Plan

Contact Person(s): Matt Fadich Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): Not applicable Corrective action planned: Task: Reviewed all nonpayroll transactions charged to federal programs and implemented coding and documentation corrections for 2026. Anticipated completion date: Done Task: Updated procedures addressing the documentation and allowability standards for nonpayroll expenditures directly charged to federal grant programs. Anticipated completion date: Done Task: Train staff with purchasing and coding authority on updated procedures, including documentation requirements and the distinction between allowable program charges and costs that may not be directly charged to federal grants. Anticipated completion date: June 30, 2026 Task: Establish a quarterly review process to identify and address potentially questionable nonpayroll transactions charged to federal programs on an ongoing basis. Anticipated completion date: June 30, 2026 School’s Out Washington considers the above steps sufficient and adequate to close the gaps in the coding of transactions that may have permitted unallowable costs to post to grants for YE2025. These steps will remedy the lapse in effectiveness experienced by School’s Out Washington’s internal controls over allowable costs.

Categories

Allowable Costs / Cost Principles

Programs in Audit

ALN Program Name Expenditures
93.566 REFUGEE AND ENTRANT ASSISTANCE STATE/REPLACEMENT DESIGNEE ADMINISTERED PROGRAMS $2.94M