Finding Text
Significant Deficiency in Internal Control over Compliance Federal Agency: U.S. Department of Justice Federal Program: Grants to Encourage Arrest Policies and Enforcement of Protection Orders Assistance Listing Number: 16.590 Direct Award Number: Not applicable Pass-Through Entity: Contra Costa County Employment and Human Services Grant Identifying Number: 15JOVW-22-GG-01810-ICJR Compliance Requirement: Reporting Criteria: Pursuant to 2 CFR §200.303, the Organization is required to establish and maintain effective internal control over the federal award that provides reasonable assurance that the Organization is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Under 2 CFR §200.328 (financial reporting) and §200.329 (performance reporting) recipients are responsible for monitoring activities under federal awards and must submit required performance and financial reports at the intervals required by the federal award, which may be no more frequent than quarterly and no less frequent than annually. Condition and Context: The pass-through entity (Contra Costa County) required use of their form D-15 for the sub awardee organization. That form required only one signature for preparation and submission. As such, a second signature was not on the form as proof of review. Cause: Management did not design and implement documented internal controls requiring supervisory review and approval of federal financial reporting. Effect: The lack of documented internal controls increased the risk that errors, omissions, or noncompliance related to reporting could occur and not be detected in a timely manner. Questioned Costs: Not applicable. Repeat Finding: No Recommendation: We recommend management design and implement documented review and approval controls over the applicable compliance requirements. This should include regular monitoring to ensure controls are consistently applied, and periodic internal audits to assess the effectiveness of compliance systems.Views of Responsible Officials: The Organization is a subrecipient of this grant administered by Contra Costa County. We used one signature during 2025 for preparer and submitter of the financial reporting as has been acceptable to the Contra Costa County for acceptance and processing. Although there was evidence of internal review within the accounting department, the Organization understands the need for second review documentation. A process will be implemented beginning in January 2027 to document the second review signature.