Finding 1228064 (2023-002)

Material Weakness Repeat Finding
Requirement
BCL
Questioned Costs
-
Year
2023
Accepted
2026-08-27

AI Summary

  • Core Issue: Internal controls over financial statement preparation and grant compliance are inadequate, leading to potential misstatements and reporting errors.
  • Impacted Requirements: Compliance with GAAP and federal regulations is at risk, affecting the accuracy of financial statements and the Schedule of Expenditures of Federal Awards (SEFA).
  • Recommended Follow-Up: Strengthen internal controls by assigning qualified personnel for financial close processes and implementing supervisory reviews to ensure accurate reporting.

Finding Text

SCHEDULE OF FINDINGS AND QUESTIONED COSTS Financial Statement Findings and Questioned Costs September 30, 2023 Comment #2023-002 INTERNAL CONTROLS OVER FINANCIAL STATEMENT PREPARATION, GRANT CLOSE OUT AND COMPLIANCE WITH RELATED PROVISIONS OF GRANTS AND CONTRACTS SHOULD BE IMPROVED HEAD START AND SUPPORTIVE SERVICES FOR VETERAN FAMILIES PROGRAM FAL # 93.600 AND 64.003 Condition: As part of our auditing procedures, we assisted in the preparation of the financial statements, related disclosures, and the schedule of expenditures of federal awards of the Authority. The preparation of these financial statements is in accordance with generally accepted accounting principles (GAAP) and Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, is the responsibility of the grantee. The authoritative and regulatory standards states in summary, that management should authorize, process, reconcile and close-out each grant and contract in a timely manner to ensure proper accounting and reporting of such activity in accordance with the specific professional standards and regulatory requirements. The close-out process is designed to reduce the risk of errors, fraud, material misstatement of financial and compliance reporting and recognition of expenditures (or revenue) in the proper period. We noted that the current system of internal controls over financial statements and compliance is not designed to ensure that the objectives are achieved. Further, the capacity and experience of the current staff does not allow for adequate analysis of grants and contracts, proper allocations of shared costs and support services provided, grantor receivables, accounts payable, deferred revenue, and the reconciliation of bank accounts accurately and in a timely manner. This resulted in adjustments necessary to properly present the financial statements and disclosures of the Authority as of September 30, 2023. We also noted significant weaknesses in internal controls over personnel payroll and the processing, maintaining and reconciling payroll activity to the general ledger and external regulatory reporting (IRS Form 941's, IRS Form 990 filings, state filings, etc.) Therefore, the risk exists that grant receivables and/or cash from the various programs are not recorded properly during the reporting period (interim and annually). This condition also makes it difficult to prepare accurate external reports required by the various funding sources in a timely manner (i.e. SF-425). The SEFA may exclude pertinent information required by the Uniform Guidance. The systemic cause appears to be the untimely resignation of key personnel, a lack of personnel with the skills, knowledge, and experience with grant accounting and a weakness in the overall system of internal accounting controls and monitoring. Context: Review of internal control structure of the Authority’s in accordance with Government Auditing Standards. Criteria: Controls should be in place to ensure that financial statements are prepared in accordance with GAAP and GAS. The auditee shall prepare financial statements that reflect its financial position, results of operations or changes in net assets, and, where appropriate, cash flows for the fiscal year audited. The auditee shall also prepare a schedule of expenditures of Federal awards for the period covered by the auditee's financial statements. [2 CFR §200.510(a) and (b)] (Continued) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§200.327 Financial reporting and 200.328 Monitoring and reporting program performance [2 CFR §200.302(b)(2)]. When applicable to a single audit, the auditor must report as audit findings, significant deficiencies and material weaknesses in internal control over major programs (2 CFR §200.516(a)). In addition, Government Auditing Standards require auditors to report as findings significant deficiencies and material weaknesses in internal control over financial reporting identified during the audit. Effect: The risk exists that financial statements, the SEFA and other accounts and disclosures (including cash, fixed assets, grant-related receivables, deferred revenue, allocations, and cash) may not be recorded properly during the reporting period (interim and annually) and that errors may not be prevented, or detected and corrected, on a timely basis. This condition may also make it difficult for the Authority to prepare accurate and timely external reports required by various regulatory agencies and funding sources (for example, the SF-425, where applicable) and may increase the risk of noncompliance with grant and contract requirements. Cause: The cause appears to be, which may include one or more of the following: untimely resignation or turnover of key personnel; limited availability of personnel with sufficient training and experience in nonprofit and grant accounting and related compliance reporting; changes in systems and/or processes that were not accompanied by commensurate controls; and policies and procedures not being followed consistently throughout the year. Recommendation: We recommend that the Authority strengthen internal controls over the month-end and year-end financial reporting close process and grant/contract closeout activities. At a minimum, the Authority should: 1. Assign qualified personnel (internal staff and/or qualified third-party support under appropriate management oversight) to perform and document key monthly close procedures, including timely bank reconciliations, review of receivables and deferred revenue, review of grant activity, and review/approval of journal entries. 2. Implement and document supervisory review controls over the preparation of financial statements, related disclosures, and the SEFA, including review of significant estimates, allocations, and reconciliations. 3. Establish a compliance calendar and documented procedures to support timely, accurate external regulatory reporting, including IRS Forms 941, IRS Form 990, Form 5500, applicable state filings, and grantor reports such as the SF-425 and other State department filings, where applicable. 4. Provide targeted training and/or hire/retain personnel with appropriate nonprofit and grant accounting experience, including Uniform Guidance reporting requirements, commensurate with the Authority’s size and complexity. (Continued) 5. Update and consistently follow written accounting policies and procedures, including documented reviews and retention of support for key controls. Views of Responsible Officials and Planned Corrective Actions: We concur with this finding - Management is in the process of assessing the organizational structure and capacity to provide adequate financial reporting. With Board review and approval of the Authority’s financial funding sources, the Authority will hire additional fiscal clerk to further support financial requirements and segregation of duties to ensure adequate internal controls are fully implemented. The CFO will have the overall responsibility of properly reconciling and closing out the accounting system and grant activity each month in an efficient and timely manner to eliminate the risk of significant errors occurring. Budget-to-actual schedules will be an integral part of the grant accountant analyst’s basic responsibilities. The fiscal policies and procedures will be updated with the enhancements implemented within the fiscal department. Staff will be trained on revised policies and procedures and Uniform Guidance regulations. All enhancements will be implemented by September 30, 2026.

Corrective Action Plan

August 20, 2026 To: Clausell & Associates, P.C. From: Mary Harrison, Executive Director of CSRA Economic Opportunity Authority, Inc. Below is the Authority’s corrective action plan as it relates to the findings for the fiscal year ending September 30, 2023, Single Audit Act audit. Comment #2023-001 INTERNAL CONTROLS OVER FINANCIAL STATEMENT PREPARATION, GRANT CLOSE-OUT, AND COMPLIANCE WITH RELATED PROVISIONS OF GRANTS AND CONTRACTS SHOULD BE IMPROVED GENERAL Views of Responsible Officials and Planned Corrective Actions: We concur with this finding. Management is in the process of assessing the organizational structure and capacity to provide adequate financial reporting. With Board review and approval of the Authority’s financial funding sources, the Authority will require additional specialize training for fiscal staff and improve in the segregation of duties to ensure adequate internal controls are fully implemented. The Executive Director will have the overall responsibility of properly reconciling and closing out the accounting system and grant activity each month in an efficient and timely manner to eliminate the risk of significant errors occurring. Budget-to-actual schedules will be an integral part of the grant accountant analyst’s basic responsibilities. The fiscal policies and procedures will be updated with the enhancements implemented within the fiscal department. Staff will be trained on revised policies and procedures and Uniform Guidance regulations. The Executive Director will take the lead in financial reporting to ensure that all reporting meet GAAP and GAS requirements and to provide informative reports for Board and Management. All enhancements will be implemented by September 30, 2026. Concerning the preparation of external reports required by various funding sources (i.e., SF-425, DHS’s reports for LIHEAP, etc.), the Authority will ensure adequate training is performed to improve the skills and knowledge of key personnel. Policies and procedures will also be revised to support external reporting. Implementation Date: The plan correction date will be completed no later than September 30, 2026 Responsible Person: Mary Harrison, Executive Director, will be responsible for the corrective action. Comment #2023-002 INTERNAL CONTROLS OVER FINANCIAL STATEMENT PREPARATION, GRANT CLOSE-OUT, AND COMPLIANCE WITH RELATED PROVISIONS OF GRANTS AND CONTRACTS SHOULD BE IMPROVED HEAD START AND SUPPORTIVE SERVICES FOR VETERAN FAMILIES PROGRAM FAL # 93.600 AND 64.003 (Questioned Costs - None) Views of Responsible Officials and Planned Corrective Actions: We concur with the finding. Management and staff are in the process of assessing and updating the policies and procedures over the accounting and reporting of federal and state grants and contracts. In connection with training staff on grant accounting, we are providing ongoing training on the requirements of the Uniform Guidance and the specific requirements for each individual grant award as outlined in each applicable Compliance Supplement issued by Office of Management and Budget (OMB). We are currently reconciling all cash accounts and completing and amending, where necessary, all SF-425 reports and other external reports required by each funding source (state and federal). We anticipate completing this corrective action by September 30, 2026. See also the response to Comment #2023-001. Implementation Date: The plan correction date will be completed no later than September 30, 2026. Responsible Person: Mary Harrison, Executive Director, will be responsible for the corrective action.

Categories

Reporting Internal Control / Segregation of Duties Allowable Costs / Cost Principles

Other Findings in this Audit

  • 1228063 2023-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.600 HEAD START $14.89M
64.033 VA SUPPORTIVE SERVICES FOR VETERAN FAMILIES PROGRAM $1.80M
93.499 LOW INCOME HOUSEHOLD WATER ASSISTANCE PROGRAM $1.41M
93.569 COMMUNITY SERVICES BLOCK GRANT $1.04M
10.558 CHILD AND ADULT CARE FOOD PROGRAM $874,023
81.042 WEATHERIZATION ASSISTANCE FOR LOW-INCOME PERSONS $489,339
93.568 LOW-INCOME HOME ENERGY ASSISTANCE $274,400
14.169 HOUSING COUNSELING ASSISTANCE PROGRAM $103,644
14.241 HOUSING OPPORTUNITIES FOR PERSONS WITH AIDS $74,802
14.231 COVID-19 EMERGENCY SOLUTIONS GRANT PROGRAM $68,626
14.267 CONTINUUM OF CARE PROGRAM $56,720
14.871 SECTION 8 HOUSING CHOICE VOUCHERS $13,559
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $9,526
93.569 COVID-19 COMMUNITY SERVICES BLOCK GRANT $8,391
97.024 COVID-19 EMERGENCY FOOD AND SHELTER NATIONAL BOARD PROGRAM $1,776
93.568 COVID-19 LOW-INCOME HOME ENERGY ASSISTANCE PROGRAM $119