Finding 1238291 (2025-002)

Material Weakness Repeat Finding
Requirement
P
Questioned Costs
-
Year
2025
Accepted
2026-09-29
Audit: 413145
Organization: St. Mary's Community Services (CA)

AI Summary

  • Core Issue: The Organization lacked adequate documentation of internal controls for managing Federal awards, particularly in key compliance areas.
  • Impacted Requirements: This deficiency affects compliance with 2 CFR §200.303, which mandates effective internal controls over Federal awards.
  • Recommended Follow-Up: Develop comprehensive written policies and procedures, establish compliance monitoring, and provide training for staff managing Federal awards.

Finding Text

Federal Program: Coronavirus State and Local Fiscal Recovery Funds (ALN 21.027) Criteria: In accordance with 2 CFR §200.303, non-Federal entities are required to establish and maintain effective internal controls over Federal awards that provides reasonable assurance the entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: The Organization did not maintain adequately documented internal controls over compliance for the Federal program. Written policies and procedures were not maintained for several compliance areas, including procurement, cash management, allowable costs, and cost allocation methodologies. In addition, significant turnover among personnel responsible for program administration contributed to inconsistent documentation of compliance-related procedures and responsibilities. Cause: The deficiency resulted from significant personnel turnover, limited formalization of compliance processes, and insufficient documentation of internal controls and compliance procedures. Effect: The lack of documented policies and formalized compliance procedures increases the risk that noncompliance with Federal requirements could occur and not be detected in a timely manner. Recommendation: We recommend the Organization develop and implement comprehensive written policies and procedures addressing applicable Uniform Guidance requirements, including procurement, cash management, allowable costs, and cost allocation. Management should also establish documented compliance monitoring procedures and provide training to personnel responsible for administering Federal awards. We noted that subsequent to year-end, the Organization developed and implemented several written policies and procedures addressing many of these compliance areas. Questioned Costs: None. Context: Audit testing did not identify any instances of noncompliance with Federal program requirements. In addition, dual-purpose testing identified certain informal controls that were operating during the period under audit. Accordingly, this matter is reported as a significant deficiency in internal control over compliance and does not result in material noncompliance with Federal program requirements. Views of Responsible Officials: Management agrees with the finding and has formalized and documented compliance policies and procedures and provided additional training to personnel responsible for Federal program administration.

Corrective Action Plan

Condition The audit identified opportunities to strengthen documentation and monitoring controls related to federal grant compliance and Uniform Guidance requirements. Corrective Action Plan Management will enhance its federal awards compliance framework by implementing formal policies, assigning responsibilities, improving monitoring procedures, and providing staff training. Actions include: • Develop and implement a Uniform Guidance Compliance Manual. • Update procurement policies to align with Uniform Guidance requirements. • Establish written policies for cash management, allowable costs, and federal grant documentation standards. • Develop and document a formal cost allocation methodology for shared program costs. • Assign and document federal award compliance responsibilities across accounting, grants management, and program staff. • Create a grant compliance monitoring checklist and implement quarterly documented compliance reviews. • Conduct Uniform Guidance training for accounting, grants, and program personnel. Responsible Official Chief Financial Officer and Grant Manager. Anticipated Completion Date October 31, 2026.

Categories

Allowable Costs / Cost Principles Procurement, Suspension & Debarment Subrecipient Monitoring Cash Management Significant Deficiency Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 1238290 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $1.80M
93.558 TEMPORARY ASSISTANCE FOR NEEDY FAMILIES $89,878