Finding 1240002 (2025-001)

Material Weakness Repeat Finding
Requirement
B
Questioned Costs
-
Year
2025
Accepted
2026-10-06
Audit: 414625
Organization: Traffick911 (TX)

AI Summary

  • Core Issue: Traffick911's internal controls failed to catch duplicate entries, leading to $86,088 in questioned costs billed to the grantor.
  • Impacted Requirements: The Uniform Guidance mandates effective internal controls for billing and reporting, which were compromised due to staff turnover and inadequate reconciliations.
  • Recommended Follow-Up: Enhance controls to prevent duplicate invoices, improve financial reviews, and ensure reconciliations align with original documentation.

Finding Text

Federal program: U.S. Department of Justice passed through the Texas Office of the Governor: Crime Victims Assistance - Assistance Listing Number (ALN) 16.575 Criteria: The Uniform Guidance requires entities to establish and maintain effective internal controls to prevent, or detect and correct, errors in the billing and reporting of Federal expenditures. The Uniform Guidance requires that all billed costs be necessary, reasonable, allocable, and adequately supported. Condition: Traffick911’s review controls failed to detect duplicate transaction entries in the general ledger, which resulted in double-booked expenses being billed to the grantor. Statement of cause: Turnover in the accounting department led to a breakdown in established internal controls. Reconciliations failed to compare monthly ledger postings against original source vouchers and management’s financial statement review failed to identify the overstated expense and liability accounts. Statement of effect: Invalid duplicate charges were requested from the grantor, constituting a material weakness in internal controls and questioned costs. Questioned costs: Known questioned costs of $86,088 were billed to ALN 16.575. This amount represents the total cumulative value of the duplicate, invalid transactions billed to the grantor identified during the audit period.Perspective information: Our testwork identified overstated health insurance expenses totaling $186,238 due to duplicate entries, of which $86,088 was billed to the grantor. This error appeared to be isolated to the health insurance billings starting in March of 2025 through year end. The entire population of health insurance expenses was reviewed as part of the audit testing. Recommendations: Implement controls to ensure invoices are not duplicated, increase financial statement review and analysis to identify and investigate unusual fluctuations from the prior period. Perform reconciliations to tie reconciliation request to the supporting documentation and original invoices. Views of responsible officials: Responsible official: Danielle Upton, Director of Finance Finding # 2025-001 Management concurs with the finding and the associated recommendations. Management acknowledges that a breakdown in the manual invoice verification workflow allowed duplicate transactions to be processed and requested for reimbursement. Upon discovering the duplicate entries, management initiated a comprehensive review of all unbilled expenditures incurred during the grant period. Sufficient eligible, previously unbilled program costs were successfully identified and substituted to fully resolve the variance for the closed grant 3245806. The remaining $45,643 of overbilled funds was deferred and will be applied to allowable billings in 2026.

Corrective Action Plan

Corrective Action: Management determined that a breakdown in the manual invoice verification workflow allowed duplicate health insurance transactions to be processed and submitted for reimbursement. Upon discovering the duplicate entries in May 2026, management conducted a comprehensive review of eligible expenditures incurred during the applicable grant periods. The review identified $102,713 in eligible program costs that had been incurred but had not previously been billed. This included $100,462 applicable to closed grant 3245806, $1,666 applicable to open grant 3245807, and $585 applicable to open grant 5325201. After accounting for these eligible, previously unbilled expenditures, the remaining variance was $45,643. The $45,643 remaining variance, associated with October, November, and December 2025 billings, was deferred and applied to allowable billings in June 2026. Traffick911 has implemented corrective measures to strengthen financial controls and prevent recurrence. The organization has hired new finance staff, contracted with a PEO to manage payroll and benefits, and instituted a monthly reconciliation of medical insurance expenses against payroll reports to ensure ongoing accuracy. Name of Contact Person: Danielle Upton, Chief Administrative Officer, (214) 685-5850, danielle@traffick911.com Projected Completion Date: Initial billing corrections were successfully finalized in June 2026. Additional oversight and internal controls regarding medical insurance expenses are on track for full implementation by December 31, 2026.

Categories

Allowable Costs / Cost Principles Cash Management Material Weakness Reporting Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1240000 2025-001
    Material Weakness Repeat
  • 1240001 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
16.575 CRIME VICTIM ASSISTANCE $33,461