Finding 1239284 (2025-004)

Material Weakness Repeat Finding
Requirement
A
Questioned Costs
-
Year
2025
Accepted
2026-09-30
Audit: 414138
Organization: Bolton Refuge House, Inc. (WI)

AI Summary

  • Core Issue: Disbursements were made without proper documented approval, violating financial policies.
  • Impacted Requirements: Lack of segregation of duties and oversight in the Amazon purchasing account increases risk of unauthorized transactions.
  • Recommended Follow-Up: Implement stronger controls by requiring documented approvals, establishing independent reviews for Amazon purchases, and monitoring compliance with disbursement policies.

Finding Text

Cash Disbursement Approval Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Continuum of Care Assistance Listing Number: 14.267 Federal Award Identification Number and Year: 2024-2025 and 2025-2026 Award Period: October 1, 2024 – September 30, 2025 and October 1, 2025 – September 30, 2026 Type of Finding: • Material Weakness in Internal Control Over Compliance and Other Matter Criteria or specific requirement: The organization's financial policies require that expenditures receive appropriate documented approval prior to payment and that duties related to authorization, custody of assets, and recordkeeping be appropriately segregated whenever practical. These controls help ensure expenditures are valid, authorized, and made in accordance with organizational policies. Condition: During testing of disbursement transactions, we noted instances in which disbursements were processed without evidence that the organization's established approval procedures were followed. In addition, the Chief Financial Officer (CFO) maintained sole access to the organization's Amazon purchasing account, including the ability to initiate purchases and process related disbursements without independent review or approval. Questioned Costs: $1,673 (known) $5,072 (likely) Context: The Organization processed disbursements related to federal programs during the audit period. The identified control deficiencies affected the Organization's controls over the authorization and monitoring of expenditures charged to federal awards. Cause: Established disbursement approval procedures were not consistently followed, and access to the Amazon purchasing platform was not structured to provide adequate oversight or segregation of duties. Effect: The absence of required approvals and the lack of segregation of duties increase the risk of unauthorized purchases, improper expenditures, and errors or irregularities not being detected in a timely manner. Repeat Finding: No Recommendation: We recommend the organization strengthen controls over purchasing and disbursement activities by requiring documented approval of all disbursements prior to payment, establishing independent review and approval of purchases made through the Amazon account, limiting sole control of purchasing accounts by assigning secondary administrative access or implementing periodic management or board review of purchasing activity, monitoring compliance with disbursement approval policies through periodic review of transactions and supporting documentation. Views of Responsible officials and planned corrective actions: Management agrees with the finding and will enhance controls over purchasing and disbursement activities. Procedures will be implemented to ensure all expenditures receive documented approval and that Amazon account activity is subject to independent review. Management will also evaluate opportunities to improve segregation of duties and oversight of purchasing transactions.

Corrective Action Plan

Cash Disbursements Approval Recommendation: We recommend the organization strengthen controls over purchasing and disbursement activities by requiring documented approval of all disbursements prior to payment, establishing independent review and approval of purchases made through the Amazon account, limiting sole control of purchasing accounts by assigning secondary administrative access or implementing periodic management or board review of purchasing activity, monitoring compliance with disbursement approval policies through periodic review of transactions and supporting documentation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Management agrees with the finding and will enhance controls over purchasing and disbursement activities. Procedures will be implemented to ensure all expenditures receive documented approval and that Amazon account activity is subject to independent review. Management will also evaluate opportunities to improve segregation of duties and oversight of purchasing transactions. Name(s) of the contact person(s) responsible for corrective action: Harley Smalstig Planned completion date for corrective action plan: January 1, 2027

Categories

Internal Control / Segregation of Duties Procurement, Suspension & Debarment Subrecipient Monitoring

Other Findings in this Audit

  • 1239285 2025-005
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.267 CONTINUUM OF CARE PROGRAM $447,452
16.575 CRIME VICTIM ASSISTANCE $92,064
14.239 HOME INVESTMENT PARTNERSHIPS PROGRAM $75,000
16.017 SEXUAL ASSAULT SERVICES FORMULA PROGRAM $70,000
93.671 FAMILY VIOLENCE PREVENTION AND SERVICES/DOMESTIC VIOLENCE SHELTER AND SUPPORTIVE SERVICES $64,749
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $29,988
14.231 EMERGENCY SOLUTIONS GRANT PROGRAM $19,128
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $14,112