Finding 1238590 (2025-002)

Material Weakness Repeat Finding
Requirement
CL
Questioned Costs
-
Year
2025
Accepted
2026-09-30
Audit: 413441
Organization: Connections to Success (MO)

AI Summary

  • Core Issue: Lack of documented management review and approval for cash drawdowns and reports, leading to significant deficiencies in internal controls.
  • Impacted Requirements: Noncompliance with Uniform Grant Guidance (2 CFR 200.303), which mandates effective internal controls for federal awards.
  • Recommended Follow-Up: Formalize and consistently apply review processes for all drawdown requests and reports, ensuring documentation of management approval is maintained.

Finding Text

2025-002 Cash Management and Reporting Federal Agency: U.S. Department of Labor Federal Program Title: Reintegration of Ex-Offenders Assistance Listing No. 17.270 Award Periods: July 1, 2023 – December 31, 2026 Type of Finding: • Significant Deficiency in Internal Control Over Compliance – Cash Management and Reporting Questioned Costs: None Condition: During our testing of five drawdown requests and four reports, CLA noted that two drawdown requests and two reports were submitted without evidence of management review and approval. The Organization did not implement its review process over drawdown requests until September 2025, therefore, the two drawdowns selected for testing that occurred prior to implementation did not have documentation of review. In addition, no review process was documented for two reports tested prior to submission. While all financial reports were prepared and submitted by the outsourced accountant, management review and approval was not documented for two of the four items tested. Criteria: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure drawdowns and reports are formally reviewed by someone who did not prepare the drawdown or report to verify the correct amount is required. Context: The Organization did not maintain adequate documentation related to internal controls over cash management and reporting. The sampling methodology used is not, and is not intended to be statistically valid. Cause: For some instances, the Organization did not have effective internal controls over compliance in place to ensure that cash management and reporting procedures were followed and documented. Effect: Failure to properly approve drawdowns, reports and maintain documentation may result in drawdown requests for unapproved or unrelated costs charged to the grant. Repeat Finding: The finding is a repeat of the prior year finding number 2024-002. Recommendation: The Organization should formalize and consistently apply its review and approval controls over drawdown requests and grant reports. Management should review all submissions prior to filing and maintain documentation evidencing the review and approval performed. Views of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

Type of Finding: Significant Deficiency in Internal Control Over Compliance – Cash Management and Reporting Recommendation: The Organization should formalize and consistently apply its review and approval controls over drawdown requests and grant reports. Management should review all submissions prior to filing and maintain documentation evidencing the review and approval performed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This finding is a repeat of prior-year finding 2024-002. The Organization implemented its documented review and approval process over federal drawdown requests in September 2025. As noted in the finding, the two drawdown requests without documented review were submitted prior to that implementation, and the remaining drawdown requests tested included documented review and approval. Building on the corrective action plan submitted for fiscal year 2024, the Organization has taken the following corrective actions: ● Beginning in September 2025, the Organization implemented a documented two-level review and approval process for all federal drawdown requests. The preparer compiles the supporting documentation, and the Operations Director reviews the request and provides written approval prior to submission. ● Documented management review and approval has been extended to ETA-9130 financial reports, which are reviewed and approved by the Operations Director prior to filing. ● The Organization's Cash Management Policy was formally updated, effective March 3, 2026, as part of the corrective action plan submitted to and approved by the U.S. Department of Labor. The policy requires written management approval prior to submission of any drawdown request, documented management review of ETA-9130 financial reports prior to filing, and retention of all approval evidence in the electronic grant file, memorializing the drawdown review procedures in practice since September 2025. ● No drawdown request or financial report is submitted until the Operations Director's written approval has been received and saved to the electronic grant file, so evidence of review and approval is retained for every submission. ● The Operations Director will conduct quarterly internal reviews to ensure this process is being followed. The drawdown review and approval process has been in practice since September 2025, and the review and approval requirements for drawdown requests and financial reports were formally documented in policy effective March 3, 2026. These controls continue to be monitored on an ongoing basis to prevent recurrence. Name(s) of contact person(s) responsible for corrective action: Cory Finley, Operations Director, with oversight by Brandi Jahnke, Chief Executive Officer Planned completion date for corrective action plan: Drawdown review and approval implemented in practice as of September 2025; review and approval requirements formalized in written policy effective March 3, 2026. The Operations Director will conduct quarterly internal reviews on an ongoing basis. If the U.S. Department of Labor has questions regarding this plan, please call Brandi Jahnke at (816) 520-4404.

Categories

Cash Management Reporting Significant Deficiency Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 1238589 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
17.270 Reintegration of Ex-Offenders $882,326
21.027 COVID 19 - Office of Violence Prevention- State and Local Fiscal Recovery Fund $370,894
93.558 Temporary Assistance for Needy Families (TANF) Youth and Family Stability Program $96,377
16.812 Second Chance Act Community-Based Reentry Program $92,200
17.805 Homeless Veterans Reintegration Program $49,065
93.558 Temporary Assistance for Needy Families (TANF) Healthy: Marriage Promotion and Responsible Fatherhood Initiatives $25,607