Criteria The Uniform Guidance requires that recipients of federal awards maintain accounting records in sufficient detail to accurately track all federal funds received and expended by programs. Organizations must ensure that expenditures are properly recorded, supported, and allocable to specific federal awards. In addition, management is responsible for the preparation of the SEFA, which must accurately reflect expenditures based on qualifying costs actually incurred and must be supported by the underlying accounting records. Further, because expenditures were not tracked at the grant level within the accounting system, UHU was unable to adequately monitor whether costs had already been allocated to a federal award. During our testing, we noted instances in which the same expenditures were used to support charges to multiple funding sources, resulting in duplicate charging ("double dipping") and overcharges to certain federal awards. CONDITION AND CONTEXT Although UHU has a policy requiring expenses to be tracked by project, program, and cost center, this policy was not consistently followed. UHU did not track federal award expenditures within the general ledger using separate cost centers for each grant. Instead, expenses were initially recorded without appropriate grant-level coding and were subsequently assigned to federal programs based on billings and other documentation. Additionally, for two projects where federal funds totaling $1,082,381 were received in advance, UHU was unable to provide adequate supporting documentation, such as billings or other records, to substantiate the expenditures charged to those programs. As a result, there was insufficient evidence to demonstrate that the funds were expended in accordance with grant requirements or that qualifying costs were incurred. These deficiencies also affected the preparation of the SEFA, because expenditures were not tracked at the grant level within the accounting system and were subsequently assigned using secondary documentation. As such the amounts reported on the SEFA were not directly supported by the underlying accounting records. Furthermore, for the projects with advance funding, the lack of supporting documentation limited management’s ability to substantiate that the reported expenditures represented qualifying costs actually incurred during the period. Accordingly, the SEFA was prepared using information that could not be fully reconciled to, or supported by, the general ledger, reducing the reliability and supportability of the reported federal expenditures. Cause - Management did not enforce existing policies requiring expenditures to be tracked by project, program, and cost center within the accounting system at the time transactions were recorded. As a result, expenses were not consistently captured at the grant level in the general ledger, and management relied on retrospective determinations and allocations based on billing records, which were incomplete or unavailable in certain instances. Additionally, UHU did not maintain sufficient supporting documentation to substantiate expenditures, particularly for projects where funds were received in advance. The lack of grant-specific tracking and reconciliation procedures also prevented management from identifying expenditures that had previously been charged to other funding sources, increasing the risk that the same costs would be allocated to multiple awards. EFFECT OR POTENTIAL EFFECT- As a result, expenses were charged to federal programs without adequate supporting documentation. This raises the risk that unallowable costs were charged to the grants, and the accuracy of the SEFA could not be verified. UHU is not in compliance with the requirements of the Uniform Guidance, and this deficiency contributed to the basis for our qualified opinion under the Uniform Guidance. Additionally, because expenditures were not tracked and monitored by specific federal award within the accounting records, UHU charged certain costs to federal awards more than once. As a result, federal programs were overcharged for expenditures that had previously been allocated to other funding sources, resulting in questioned costs and noncompliance with the allowability and allocability requirements of Uniform Guidance. The lack of adequate expenditure tracking prevented management from detecting and correcting these duplicate charges in a timely manner. Furthermore, because the SEFA is derived directly from the underlying accounting records, the lack of contemporaneous tracking of expenditures by grant and insufficient supporting documentation increases the risk that the SEFA is incomplete, inaccurate, or not supported by qualifying costs actually incurred. This impacts the reliability of the SEFA as supplementary information to the financial statements. Recommendation - Management should enforce existing policies requiring expenditures to be recorded by project, program, and cost center within the general ledger at the time transactions are incurred and reconciled periodically to supporting grant records and funding source reports. Controls should be established to ensure that all federal award expenditures are properly coded to the appropriate grant, charged to only one funding source, and supported by sufficient documentation, including invoices, payroll records, contracts, or other relevant evidence demonstrating that costs are allowable, allocable, and adequately supported in accordance with the Uniform Guidance. Management should also implement procedures to ensure that funds received in advance are appropriately monitored and supported by documentation demonstrating that qualifying expenditures have been incurred prior to being reported as federal expenditures. In addition, management should eliminate reliance on retrospective allocations and instead maintain accurate accounting records that directly support financial reporting and federal reporting. Management should implement reconciliation and review controls to ensure expenditures are not duplicated across multiple grants, federal awards, or other funding sources. Such controls should include periodic reconciliations of grant expenditures to the general ledger, supporting documentation, funding source records, and the SEFA, as well as a review of allocation methodologies and cost transfers. Reconciliations should be designed to identify and resolve duplicate charges, unsupported expenditures, and allocation errors on a timely basis and should be reviewed and approved by management. Documentation supporting all cost transfers, allocation adjustments, and reconciliations should be maintained. Periodic reconciliations between the general ledger, supporting documentation, and the SEFA should be performed and reviewed by UHU to ensure completeness, accuracy, and compliance with federal reporting requirements. These reconciliations should be reviewed by management. Strengthening these controls will improve compliance with the Uniform Guidance, enhance the reliability of reporting, and reduce the risk of questioned costs and audit findings.