Finding 1239208 (2025-002)

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

AI Summary

  • Core Issue: Two out of five grant claims lacked a formal review by someone other than the preparer, violating internal control standards.
  • Impacted Requirements: Compliance with cash management criteria, including accurate claims and proper segregation of duties.
  • Recommended Follow-Up: Implement a formal review process for grant claims, ensuring documentation of review, signatures, and dates before submission.

Finding Text

Federal Agency: U.S. Department of Agriculture Federal Program Name: Environmental Quality Incentives Program Assistance Listing Number: 10.912 Federal Award Identification Number and Year: NR243A750011G009 - 2024 Award Period: 9/1/24-9/29/29 Type of Finding: Significant Deficiency in Internal Control over Compliance Compliance Requirement: Cash Management Criteria or specific requirement: Grant claims filed by the Organization to granting agencies must be accurate, reconcile to the Organizations general ledger system and for cost-reimbursable grants, represent costs incurred. Internal controls should be signed and implemented to prevent and detect errors in the data reported on the grant claims. Segregation of duties is an internal control intended to prevent or decrease to occurrence of errors or intentional fraud. Segregation of duties ensure that no single employee has control over all phases of a transaction. There should be a secondary review of each grant claim prior to being certified and filed to ensure that there are no errors, irregularities, or misrepresentations. Condition: Of the 5 claims for reimbursement selected for testing, noted 2 did not have a formal review documented by someone other than the preparer. Accordingly, this does not allow for a proper segregation of duties for internal control purposes over the cash management compliance requirement. Questioned costs: None Context: While performing audit procedures, it was noted that two of five grant claims tested that were submitted for reimbursement did not have formal documentation of review by someone other than the preparer. This was a finding in the prior year audit and a plan was put into place in September 2025 to address the issue but was not implemented for part of the period under audit. Cause: Due to the timing of when the formal procedures were put in place. Effect: Over- or under-reporting certain items for reimbursement on claims if there are no reviews in place. Repeat Finding: Repeat Finding 2024-003 Recommendation: We recommend the Organization implement a formal control where someone other than the preparer document their review of the claim prior to submitting to the federal agency. This review would include comparing the amounts in the report to the general ledger or other supporting documents. This review should be supported by documenting the signature and date prior to submission. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

Environmental Quality Incentives Program – Assistance Listing No. 10.912 Recommendation: We recommend the Organization implement a formal control where someone other than the preparer documents their review of the claim prior to submitting to the federal agency. This review would include comparing the amounts in the report to the general ledger or other supporting documents. This review should be supported by documenting the signature and date prior to submission. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Status of corrective action: This finding recurred because the controls below were implemented in October 2025 and were not in place for the full 2025 audit period. We expect it to be resolved in the 2026 audit. Claim preparation and independent review: For each claim, the Grants Manager or designee prepares a Claim/Billing Approval Form and routes it, with the supporting documentation, to the Project Manager. The Project Manager, who does not prepare the claim, compares the amounts on the claim to the general ledger and to supporting documentation such as payroll allocation reports and vendor invoices, and resolves any differences with the preparer before approving. Signature and date prior to submission: Both the preparer and the reviewer electronically sign and date the Claim/Billing Approval Form. The claim is not initiated in the funder portal until the form is fully approved, so the documented approval date will always precede the submission date. Documentation and monitoring: The approved form, supporting documentation, and portal submission confirmation are saved together in the Organization's grant files. A member of management will periodically review a sample of submitted claims to confirm that the review was completed, signed, and dated before submission. Name(s) of the contact person(s) responsible for corrective action: Jill Matchett, Grants Manager through June 2026, Lori Hall, Grants Manager June 2026 - present Planned completion date for corrective action plan: Implemented October 2025; expected to be resolved in the audit for the year ending December 31, 2026

Categories

Cash Management Internal Control / Segregation of Duties HUD Housing Programs Reporting Significant Deficiency

Other Findings in this Audit

  • 1239207 2025-001
    Material Weakness Repeat
  • 1239209 2025-003
    Material Weakness Repeat
  • 1239210 2025-004
    Material Weakness Repeat
  • 1239211 2025-005
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
10.912 Environmental Quality Incentives Program $725,547
10.937 Partnerships for Climate-Smart Commodities $529,243
10.311 Beginning Farmers and Ranchers Development Program $110,252
10.902 Soil and Water Conservation $80,549
10.443 OUTREACH AND ASSISTANCE FOR SOCIALLY DISADVANTAGED AND VETERAN FARMERS AND RANCHERS $33,807
10.164 Wholesale Farmers and Alternative Market Development $16,142