Finding 1238514 (2025-002)

Material Weakness Repeat Finding
Requirement
B
Questioned Costs
-
Year
2025
Accepted
2026-09-30

AI Summary

  • Core Issue: The Association lacks formal procedures for reviewing and approving stipend costs, risking noncompliance with federal requirements.
  • Impacted Requirements: Compliance with 2 CFR sections 200.303 and 200.403 regarding internal controls and allowable costs.
  • Recommended Follow-Up: Establish a formal review process for stipend payments, including standardized documentation for approvals and calculations.

Finding Text

Finding Type: Significant Deficiency in Internal Control Over Compliance Title and ALN of Federal Program: 93.558 – Temporary Assistance for Needy Families Criteria or Specific Requirement: B. Allowable Costs and Cost Principles - 2 CFR section 200.303 of the Uniform Guidance requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. In addition, 2 CFR section 200.403 provides that costs charged to a Federal award must be necessary, reasonable, allocable, adequately documented, and in conformance with applicable Federal requirements and the terms and conditions of the Federal award. Condition: During the audit, it was noted that the Association was unable to provide formal support for the internal review and approval of costs relating to stipends paid that were submitted to the pass-through grantor under the major program. Cause: The Association lacks established procedures which provide formal evidence that the allowability, accuracy and completeness of stipend transactions were verified before submission. Effect or Potential Effect: Although no stipend payments were identified which exceeded the allowable amount under the subaward agreement, without adequate controls in place to ensure all charges to the federal program are properly reviewed and approved for allowability, the Association faces increased risk of noncompliance with the allowability requirement and could request funds for unallowed costs. Questioned Costs: None. Identification as a Repeat Finding: N/A — this was not reported as a finding in the prior year audit report. Context: For the stipend payments selected for testing, there was no formal support for the internal review and approval of costs submitted to the pass-through grantor under the major program. Recommendation: We recommend the Association implement a formal process for review and approval of stipend payments. This should include maintenance of a standardized stipend calculation form or comparable documentation for each payment. The documentation should identify the participant, applicable payment period, attendance and participation records and/or milestones achieved, calculation of the stipend amount, and evidence of review and approval before payment. Views of Responsible Officials: Management agrees with the finding and recommendation.

Corrective Action Plan

Finding Number: 2025-02 Condition: During the audit, it was noted that the Association was unable to provide formal support for the internal review and approval of costs relating to stipends paid that were submitted to the pass-through grantor under the major program. Planned Corrective Action: The Godman Guild Association has an existing process for reviewing and approving stipend payments. The Association has shored up existing processes by implementing a consistent documentation format that identifies the applicable participant and payment period and includes supporting participation records, the stipend calculation, and reviewer approval. As an additional internal review procedure, program participant listings submitted to grantors will be periodically reconciled to supporting enrollment and eligibility documentation to provide an additional level of oversight of participant eligibility and grant reporting. The Association will retain all documentation with the applicable grant records to maintain a consistent record of the review and approval process. Contact Person Responsible for Corrective Action: Solonas Karoulla, Chief Advancement Officer, solo.karoulla@godmanguild.org Completion Date: September 30, 2026

Categories

Allowable Costs / Cost Principles Subrecipient Monitoring

Other Findings in this Audit

  • 1238515 2025-004
    Material Weakness Repeat
  • 1238516 2025-004
    Material Weakness Repeat
  • 1238517 2025-004
    Material Weakness Repeat
  • 1238518 2025-003
    Material Weakness Repeat
  • 1238519 2025-004
    Material Weakness Repeat
  • 1238520 2025-004
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.667 SOCIAL SERVICES BLOCK GRANT $477,810
84.002 ADULT EDUCATION - BASIC GRANTS TO STATES $183,913
93.558 TEMPORARY ASSISTANCE FOR NEEDY FAMILIES $154,197
10.561 STATE ADMINISTRATIVE MATCHING GRANTS FOR THE SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM $28,708
16.540 JUVENILE JUSTICE AND DELINQUENCY PREVENTION $25,000