Finding 1223236 (2023-001)

Material Weakness Repeat Finding
Requirement
P
Questioned Costs
-
Year
2023
Accepted
2026-07-08

AI Summary

  • Core Issue: The Fund lacks proper segregation of duties in accounting, increasing the risk of errors and fraud.
  • Impacted Requirements: Ideal internal controls are not met due to the small staff size, making complete segregation economically unfeasible.
  • Recommended Follow-Up: Enhance management and board oversight, identify high-risk areas, and implement limited segregation where possible to mitigate risks.

Finding Text

Financial Statement Finding - LACK OF SEGREGATION OF DUTIES Criteria: A fundamental concept in a good system of internal controls is the segregation of duties. Duties should be separated so that no one person performs incompatible duties or has complete control of any type of transaction. Condition: The Fund does not currently have an internal control system to allow for proper segregation of duties in certain areas of the accounting duties. Cause: Due to the relatively small size of the Fund’s staff, the Fund is not able to attain segregation of duties to the extent required for ideal internal control. This is not unusual in an organization of this size, and generally it is not economically feasible to provide for complete adherence to the segregation of duties concept. Effect: Proper segregation of duties helps minimize the chance of undetected errors and if not mitigated there is potential of misappropriation of assets. Recommendation: Due to the small size of the Fund, there is limited options available to them. Under this situation, the most effective control is management and the board’s oversight and knowledge of the matters relating to the operations of the Fund. Views of Responsible Officials and Planned Corrective Actions The Fund’s management is aware of this condition and believes that it is not economically feasible to attain the ideal segregation of duties. Management attempts to mitigate the associated risks by doing the following: (1) Identifies areas where the lack of segregation of duties exists and where there are higher risks of errors or fraud occurring. (2) Implements limited segregation to the extent possible to reduce risks without impairing efficiency. (3) Uses the knowledge that management and the Board of Directors has of operations by having them review certain accounting records and reports. (4) Monitors the effectiveness of the above actions and makes changes as considered appropriate.

Corrective Action Plan

Management agrees with this finding. Because the Fund operates with a relatively small administrative staff, complete segregation of incompatible duties is not always feasible. Management and those charged with governance recognize this as an inherent limitation of the current organizational structure rather than an intentional departure from sound control practices. To address this limitation, the Fund will strengthen compensating oversight controls. These measures will include increased review of disbursements, bank activity, journal entries, and selected account activity by senior management and periodic reporting to the Board of Directors or its designated governance committee. Existing mitigating controls include management familiarity with operations, review of significant cash disbursements, and governance oversight at regular meetings; however, these controls will be formalized and documented more consistently. Corrective action plan: • Implement a documented monthly review of cash disbursements, bank statements, journal entries, and unusual transactions by the General Manager or equivalent executive not performing day-to-day bookkeeping functions. • Require Board of Directors or finance committee review of summarized financial information, check registers, and budget-to-actual results at regular meetings. • Establish approval thresholds requiring dual review for significant non-routine disbursements, vendor additions, write-offs, and manual journal entries. • Document evidence of supervisory review through sign-off or electronic approval retention. Responsible party/role: General Manager, Business Office Manager, Staff Accountant, and Board of Directors. Implementation timeline: Initial compensating control procedures will be implemented within 90 days of issuance of the audit report, with board-level reporting enhancements in place by June 30, 2026.

Categories

Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1223237 2023-002
    Material Weakness Repeat
  • 1223238 2023-003
    Material Weakness Repeat
  • 1223239 2023-004
    Material Weakness Repeat
  • 1223240 2023-005
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
11.029 TRIBAL BROADBAND CONNECTIVITY PROGRAM $3.43M
21.029 CORONAVIRUS CAPITAL PROJECTS FUND $205,201
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $167,504