Finding Text
Criteria: According to 2 CFR 200.512(a)(1) of the Office of Management and Budget's Uniform Guidance, the audit, data collection form, and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after the auditee receives the auditor's reports or nine months after the end of the audit period. These submissions are a key part of ensuring transparency and compliance with federal funding requirements for the Child Nutrition Cluster Programs. Deviation/Condition: The Organization did not submit the Data Collection Form and reporting packages to the Federal Audit Clearinghouse (FAC) within the required time frame. This failure to meet the deadline constitutes a significant deficiency in internal controls, as it delays the required reporting and could impact the federal oversight of program funds. Known/Likely Questioned Costs: There are no questioned costs associated with this finding, as the delay does not involve improper use of federal funds, but rather the timing and submission of required documentation. Cause: The delay in submission occurred due to lapses in the Organization’s internal processes for managing and tracking deadlines. There was also a lack of consistent monitoring of the compliance calendar and the reminders that had been set in place to facilitate timely submission. The Organization has identified these gaps as the primary cause of the issue. Possible Asserted Effect: Although there are no questioned costs, the failure to submit the required forms and reports in a timely manner could negatively impact the Organization’s relationship with the federal oversight agencies, as well as the integrity of its internal controls. Additionally, it may cause delays in subsequent audits and reporting, affecting the program’s ongoing compliance status. Perspective: From the Organization’s perspective, the issue was not intentional but resulted from gaps in internal controls and inadequate planning. The Organization has acknowledged these deficiencies and is committed to improving its processes to ensure compliance moving forward. Corrective actions are already in progress. Repeat Exception: This is a repeat finding, as similar issues were identified in the prior audit period regarding the timeliness of submissions. Although the corrective action is partially implemented, the finding remains open, indicating that the problem has not been fully resolved. Recommendation: It is recommended that the Organization: 1. Appoint a member to be responsible for monitoring the compliance calendar that tracks all required submission deadlines and includes automatic reminders to ensure timely reporting. 2. Engage with the audit firm early in the year to schedule audit work and align timelines with internal deadlines to allow sufficient time for the audit process. 3. Increase the involvement of the Board of Directors in overseeing the financial reporting and audit process, ensuring that accountability is established at the highest level. 4. Continue training staff involved in reporting and the Child Nutrition programs, with a focus on timely submission and compliance with all federal reporting requirements. 5. Implement an organized filing system for all Child Nutrition programs’ documents to make information and documents easily accessible for the Organization and the auditors. Views of Responsible Official: Nisson Portnoy, Food Program Director, is the responsible official for the Organization. He agrees with the audit findings and the associated recommendations. The Organization has already made progress on implementing corrective actions, including staff training, improved internal tracking and monitoring, and is working to develop an organized and efficient document management system. The Organization is committed to further enhancing internal controls and ensuring future compliance with all deadlines. Confidential and Sensitive Info: Financial and operational documents referenced in this audit finding, including internal compliance procedures and staff training materials, contain sensitive information. These documents are confidential and have been shared with the audit team under a confidentiality agreement.