Finding Text
Criteria Under 2 CFR 200.303, non-Federal entities are required to establish and maintain effective internal controls over Federal awards. In addition, 2 CFR 200.334 requires financial and programmatic records supporting Federal awards to be retained and made available for examination. Condition During testing of expenditures and related reimbursement requests for compliance with the period of performance compliance requirement, the Organization was unable to provide the original reimbursement request summary supporting certain selected drawdowns. Management subsequently regenerated expenditure detail for the applicable billing periods and provided supporting documentation supporting eligible program expenditures in excess of the amounts requested for reimbursement. Cause The Organization did not maintain adequate controls to ensure reimbursement request documentation was retained and readily accessible to support amounts claimed under the Federal award. Effect The inability to maintain and readily provide supporting reimbursement documentation increases the risk that noncompliance with Federal program requirements may not be timely detected and may impair monitoring and audit activities. The lack of retained documentation also limits the ability to efficiently demonstrate compliance with Federal award requirements. Recommendation We recommend that the Organization strengthen document retention procedures to ensure reimbursement request packages and supporting documentation are maintained and readily accessible for review to support federal expenditures and reimbursement requests. Views of Responsible Officials and Planned Corrective Action Management agrees with the finding and will implement procedures to ensure reimbursement request documentation and supporting schedules are retained in a centralized location and readily accessible for future monitoring and audit purposes.