Finding 1225298 (2024-004)

Material Weakness Repeat Finding
Requirement
C
Questioned Costs
-
Year
2024
Accepted
2026-07-31

AI Summary

  • Core Issue: Lack of documented review and approval for drawdown requests, which violates federal internal control requirements.
  • Impacted Requirements: Non-compliance with 2 CFR 200.303 and internal control standards, leading to potential cash management issues.
  • Recommended Follow-up: ICFJ should establish clear procedures for independent review and approval of drawdown requests, ensuring all documentation is properly filed and accessible.

Finding Text

Finding 2024-004 Cash Management Federal Agencies: U.S. Department of State and U.S. Agency for International Development Federal Programs: International Programs to Support Democracy, Human Rights and Labor and Foreign Assistance for Programs Overseas Assistance Listing Numbers: 19.345 and 98.001 Pass-through Entity: None Award Identification Number and Year: S-LMAQM-20-GR-2099, S-LMAQM-20-GR-2100, SAQMIP- 22-GR-0005, S-AQMIP-23-GR-0343, 720-523-18-CA-00006, 720-486-23-LA-00001 Criteria or Specific Requirement: Under 2 CFR 200.303, organizations that receive Federal funding are required to “establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award." These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Evidence of review/approval for certain drawdown requests could not be provided. The supporting documentation for certain requests (i.e. the schedule documenting the calculation for the amount requested) was also not available. While management asserts that a review and approval of drawdown requests occurred, there is no audit trail that shows the evidence of the control occurring. Cause: ICFJ experienced transition during the fiscal year and certain documents were unable to be located during the audit process. Effect or Potential Effect: Appropriate procedures and documentation for drawdown requests is important to ensure compliance with cash management compliance requirements. Questioned Costs: None Context: Our audit procedures consisted of testwork performed over cash receipts and drawdown requests from the Federal Government. We consider our sample to be representative of the population. The condition appears to be systemic in nature. Identification as a Repeat Finding, if Applicable: This is a repeat finding (2023-004) Recommendation: We recommend that management of ICFJ implement procedures and control processes to incorporate and document an independent review and approval, evidenced by a signature/initialing and date of the review and approval taking place prior to submission to the funder. Each request should be filed with the documentation supporting the calculation of the request.

Corrective Action Plan

Views of Responsible Officials: Management acknowledges this finding, which is a repeat of finding 2023-004. While management believes that appropriate review and approval of drawdown requests occurred during the fiscal year, we recognize that the lack of documented evidence constitutes a control weakness. ICFJ will implement a formal drawdown request procedure requiring that each request be accompanied by a supporting calculation schedule and documented evidence of independent review and approval, evidenced by signature and date, prior to submission to the funder. All drawdown documentation will be filed centrally and maintained for audit retrieval.  Anticipated completion date: 9/30/26  Responsible position: Chief Financial Officer

Categories

Cash Management Subrecipient Monitoring Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 1225275 2024-001
    Material Weakness Repeat
  • 1225276 2024-003
    Material Weakness Repeat
  • 1225277 2024-004
    Material Weakness Repeat
  • 1225278 2024-005
    Material Weakness Repeat
  • 1225279 2024-001
    Material Weakness Repeat
  • 1225280 2024-003
    Material Weakness Repeat
  • 1225281 2024-004
    Material Weakness Repeat
  • 1225282 2024-005
    Material Weakness Repeat
  • 1225283 2024-001
    Material Weakness Repeat
  • 1225284 2024-003
    Material Weakness Repeat
  • 1225285 2024-004
    Material Weakness Repeat
  • 1225286 2024-005
    Material Weakness Repeat
  • 1225287 2024-001
    Material Weakness Repeat
  • 1225288 2024-003
    Material Weakness Repeat
  • 1225289 2024-004
    Material Weakness Repeat
  • 1225290 2024-005
    Material Weakness Repeat
  • 1225291 2024-001
    Material Weakness Repeat
  • 1225292 2024-002
    Material Weakness Repeat
  • 1225293 2024-003
    Material Weakness Repeat
  • 1225294 2024-004
    Material Weakness Repeat
  • 1225295 2024-001
    Material Weakness Repeat
  • 1225296 2024-002
    Material Weakness Repeat
  • 1225297 2024-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
98.001 USAID FOREIGN ASSISTANCE FOR PROGRAMS OVERSEAS $496,531
19.221 REGIONAL DEMOCRACY PROGRAM $302,000
19.900 AEECA/ESF PD PROGRAMS $212,749
19.345 INTERNATIONAL PROGRAMS TO SUPPORT DEMOCRACY, HUMAN RIGHTS AND LABOR $143,345
19.415 PROFESSIONAL AND CULTURAL EXCHANGE PROGRAMS - CITIZEN EXCHANGES $113,853
19.021 INVESTING IN PEOPLE IN THE MIDDLE EAST AND NORTH AFRICA $97,032
19.022 EDUCATIONAL AND CULTURAL EXCHANGE PROGRAMS APPROPRIATION OVERSEAS GRANTS $48,765
19.750 BUREAU OF WESTERN HEMISPHERE AFFAIRS ASSISTANCE COORDINATION (WHA/AC) GRANT PROGRAMS $39,764
19.040 PUBLIC DIPLOMACY PROGRAMS $19,514
19.108 BUREAU OF SOUTH AND CENTRAL ASIAN AFFAIRS $7,713
19.989 STATE/AFRICAN REGIONAL - OTHER ECONOMIC SUPPORT FUNDS (ESF) PROJECTS/PROGRAMS $6,054
19.501 PUBLIC DIPLOMACY PROGRAMS FOR AFGHANISTAN AND PAKISTAN $3,690
19.979 REGIONAL PEACE AND SECURITY $711