Finding 12265 (2022-004)

Material Weakness
Requirement
AB
Questioned Costs
-
Year
2022
Accepted
2023-02-13
Audit: 16547
Organization: Epilepsy Foundation of America (MD)

AI Summary

  • Core Issue: There is a material weakness in controls over allowable costs due to missing approval documentation for non-payroll expenditures.
  • Impacted Requirements: The organization failed to comply with the Uniform Guidance, which mandates proper internal controls and documentation retention.
  • Recommended Follow-Up: Management should create and implement procedures to ensure all non-payroll expenditure approvals are documented and retained.

Finding Text

Finding 2022-004: Material Weakness over Allowable Costs - Review of Non-Payroll Expenditures Information on the Federal Program: Department of Human and Health - Center for Disease Control: Improving Epilepsy Programs, Services and Outcomes Through Partnerships, CFDA 93.850 Criteria: The Uniform Guidance requires organizations to establish internal controls to detect potential noncompliance. Condition: Management has an established control in place, in that all expenditures paid through the Concur system were reviewed and approved by an appropriate project manager, but did not retain evidence of this approval occurring during the year for 9 non-payroll expenditures chosen for testing. Cause: Due to a lack of policies and procedures regarding retention of review documentation and lack of awareness of the requirement. Effect: Non-compliance with adequate review over allowable costs. Questioned Costs: There were no material questioned costs identified. Context: All expenditures approved in the Concur payables system chosen for testing did not have retained evidence of approval, totaling 15% of the non-payroll expenditures tested. Repeat Finding: No. Recommendation: We recommend that management establish procedures to document the review and approval performed over non-payroll expenditures.

Corrective Action Plan

Finding 2022-004: Material Weakness over Allowable Costs - Review of Non-Payroll Expenditures Information on the Federal Program: Department of Human and Health - Center for Disease Control: Improving Epilepsy Programs, Services and Outcomes Through Partnerships. Finding: The Uniform Guidance requires organizations to establish internal controls to detect potential noncompliance. Management has an established control in place, in that all expenditures paid through the Concur system were reviewed and approved by an appropriate project manager, but did not retain evidence of this approval occurring during the year for 9 non-payroll expenditures chosen for testing. Planned Corrective Action: We had a number of technical issues with Concur which resulted in a cessation of use in January 2022 and a transition to PN3 which was being used for payables. We transitioned to PN3 in January 2022 and are no longer using Concur. PN3 maintains all audit trails. Name and Person Responsible: Caro Marie Brown (Senior Director of Finance), June Nolan (Accounts Payable Accountant), and Lindey Camerata (Controller). Anticipated Completion Date: January 2022.

Categories

Allowable Costs / Cost Principles Material Weakness Internal Control / Segregation of Duties

Other Findings in this Audit

  • 12263 2022-002
    Material Weakness
  • 12264 2022-003
    -
  • 12266 2022-005
    Material Weakness
  • 588705 2022-002
    Material Weakness
  • 588706 2022-003
    -
  • 588707 2022-004
    Material Weakness
  • 588708 2022-005
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
93.850 Improving Epilepsy Programs, Services, and Outcomes Through National Partnerships $3.80M