Finding 1240641 (2025-002)

Material Weakness Repeat Finding
Requirement
P
Questioned Costs
-
Year
2025
Accepted
2026-10-16
Audit: 415026
Organization: JOHNSON CREEK WATERSHED COUNCIL (OR)

AI Summary

  • Core Issue: The Organization lacks an effective internal control system for tracking Federal award expenditures, relying on an external workbook instead of its accounting system.
  • Impacted Requirements: This situation violates 2 CFR 200.303 and 2 CFR 200.302, which mandate proper tracking and management of Federal funds.
  • Recommended Follow-Up: Modify the financial management system to accurately track Federal expenditures and eliminate reliance on external workbooks to ensure compliance and reliability.

Finding Text

2025-002 Finding – Federal Award Type: Material Weakness in Internal Control over Compliance – Financial Management Criteria / Requirement: In accordance with 2 CFR 200.303, non-Federal entities receiving Federal awards must establish and maintain effective internal control over Federal awards that provides reasonable assurance the awards are managed in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Additionally, 2 CFR 200.302 requires recipients to maintain financial management systems that adequately identify and account for Federal awards, support the preparation of required financial reports, and accurately track expenditures to demonstrate that Federal funds were used in accordance with applicable requirements. Condition / Context: The Organization tracked Federal expenditures charged to the grant using a workbook maintained outside of its accounting system. The accounting system was not configured or maintained to separately identify expenditures associated with the Federal award. Although most expenditures recorded in the external workbook could be reconciled to the general ledger, certain expenditures could not be traced to the accounting records. As a result, the accounting system did not provide a complete and reliable record of Federal expenditures. Cause: The Organization's financial management system was not designed or utilized to separately identify and track Federal expenditures within the accounting records. Instead, grant activity was maintained through an external workbook. Effect: The lack of an integrated financial management system increases the risk that Federal expenditures may be inaccurately recorded, charged to multiple Federal awards, include unallowable costs, or otherwise fail to comply with Federal requirements. In addition, management may be unable to demonstrate the completeness and accuracy of expenditures reported under the Federal award. Questioned Costs: None. Recommendation: We recommend the Organization modify its financial management system to separately identify and track Federal award expenditures within the accounting records. Management should discontinue reliance on external workbooks as the primary record of Federal expenditures and ensure the accounting system provides complete, accurate, and auditable records sufficient to support Federal financial reporting and compliance with Uniform Guidance requirements. Management’s Response: Management concurs with the finding and will implement effective internal controls over Financial Management

Corrective Action Plan

2025-002 Habitat Conservation – Assistance Lising #11.463 - Material Weakness in Internal Control over Compliance – Financial Management Recommendation: We recommend the Organization modify its financial management system to separately identify and track Federal award expenditures within the accounting records. Management should discontinue reliance on external workbooks as the primary record of Federal expenditures and ensure the accounting system provides complete, accurate, and auditable records sufficient to support Federal financial reporting and compliance with Uniform Guidance requirements. Explanation of disagreement with audit findings: there is no disagreement with the audit findings. Action taken in response to finding: In September 2025, Johnson Creek Watershed Council implemented a new financial management process that separately identifies and tracks Federal award expenditures within its accounting records. JCWC transitioned its bookkeeping and accounting functions to Jitasa, an external accounting firm, with QuickBooks Online serving as the official accounting ledger. Under the new process, Federal grant expenditures are coded to the appropriate grant, project, and funding source within the accounting system. Grant expenditures are reconciled to the QuickBooks general ledger and supporting documentation as part of the grant reimbursement and financial reporting process. External grant tracking worksheets may still be used as supplemental management tools for monitoring project budgets and preparing reimbursement requests; however, they are no longer relied upon as the primary record of Federal expenditures. The new Fiscal Policy Manual formalizes these practices. Section 4.4.4, Cost Allocation, requires direct costs to be charged to the specific grant, contract, or project and shared costs to be allocated using documented methodologies. Section 10.1, Financial Records, establishes QuickBooks as the official accounting ledger, with Jitasa maintaining and reconciling the organization's financial records. Action Plan: JCWC will continue the financial management process implemented in September 2025 and incorporate the process into its formal fiscal policies and procedures. The Finance & Grants Manager will work with Jitasa to ensure Federal award expenditures continue to be appropriately coded and identifiable within QuickBooks. Federal expenditures will be reviewed and reconciled to the general ledger and supporting documentation as part of ongoing grant management and reporting. The Finance & Grants Manager and Executive Director will monitor the process to ensure that external tracking worksheets remain supplemental management tools and that the official accounting records in QuickBooks remain the primary source for Federal expenditure reporting. Name(s) of the contact people responsible for correction action: Jennifer Hamilton, Executive Director Sean Connolly, Finance & Grants Manager Jitasa Mallette Faherty, Board Treasurer Plan completion date for corrective action plan: September 5, 2025 for implementation of the new process; ongoing monitoring thereafter.

Categories

Allowable Costs / Cost Principles Reporting Material Weakness Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 1240640 2025-001
    Material Weakness Repeat
  • 1240642 2025-003
    Material Weakness Repeat
  • 1240643 2025-004
    Material Weakness Repeat
  • 1240644 2025-005
    Material Weakness Repeat
  • 1240645 2025-006
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
11.463 HABITAT CONSERVATION $1.43M
15.654 NATIONAL WILDLIFE REFUGE SYSTEM ENHANCEMENTS $13,737