Finding 1240643 (2025-004)

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

AI Summary

  • Core Issue: There is a material weakness in internal controls over cash management, leading to potential inaccuracies in cash draw requests.
  • Impacted Requirements: Non-compliance with 2 CFR 200.303, 200.302, and 200.305 due to lack of supervisory review and reliance on external records.
  • Recommended Follow-Up: Implement formal internal controls, including documented reviews and a cash management policy that aligns with Uniform Guidance.

Finding Text

2025-004 Finding – Federal Award Type: Material Weakness in Internal Control over Compliance – Cash 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 support expenditures charged to Federal awards. Further, 2 CFR 200.305 requires recipients to minimize the time elapsed between the transfer of Federal funds and their disbursement for program purposes. Condition / Context: Cash draw requests were prepared and submitted by a single employee without documented supervisory review or approval. The draw requests were supported by an external workbook rather than directly by the Organization's accounting system or general ledger. Consequently, the Organization did not have documented internal controls within the cash draw process to prevent or detect inaccurate or unsupported draw requests prior to submission. Cause: The Organization had not implemented procedures requiring supervisory review and approval of cash draw requests prior to submission. In addition, cash draw requests were prepared using information maintained outside of the accounting system rather than being supported directly by the general ledger. Effect: The lack of documented review and reliance on records maintained outside the accounting system increases the risk that cash draw requests may include inaccurate, duplicate, or unallowable expenditures or amounts that are not adequately supported by the accounting records. In addition, the Organization may draw Federal funds in advance of eligible expenditures, resulting in noncompliance with the cash management requirements of 2 CFR 200.305. Questioned Costs: None. Recommendation: We recommend the Organization implement formal internal controls over the cash management process, including documented supervisory review and approval of all cash draw requests prior to submission. Cash draw requests should be prepared and supported using information maintained within the accounting system and reconciled to the general ledger to ensure that only allowable, properly recorded Federal expenditures are included in reimbursement requests. Additionally, management should develop and implement a written cash management policy that establishes procedures for preparing, reviewing, approving, reconciling, documenting, and retaining cash draw records in accordance with the Uniform Guidance. Management’s Response: Management concurs with the finding and will implement effective internal controls over Cash Management.

Corrective Action Plan

2025-004 Habitat Conservation – Assistance Lising #11.463 - Material Weakness in Internal Control over Compliance – Cash Management Recommendation: We recommend the Organization implement formal internal controls over the cash management process, including documented supervisory review and approval of all cash draw requests prior to submission. Cash draw requests should be prepared and supported using information maintained within the accounting system and reconciled to the general ledger to ensure that only allowable, properly recorded Federal expenditures are included in reimbursement requests. Additionally, management should develop and implement a written cash management policy that establishes procedures for preparing, reviewing, approving, reconciling, documenting, and retaining cash draw records in accordance with the Uniform Guidance. Explanation of disagreement with audit findings: there is no disagreement with the audit findings. Action taken in response to finding: JCWC is in the process of implementing updated financial policies and procedures to strengthen internal controls over cash management and Federal reimbursement requests. The new Fiscal Policy Manual establishes a specific process for preparing, verifying, reconciling, reviewing, approving, submitting, and retaining Federal reimbursement and cash draw requests. For example, Section 7.2.1, Reimbursement Request Process, requires: 1. Prepare and Verify The Finance & Grants Manager works with Program Staff and Jitasa to identify eligible expenditures and prepares the reimbursement request, ensuring costs are allowable, appropriately allocated, within the approved budget, and supported by documentation. The request shall be prepared using financial information maintained in QuickBooks. 2. Review and Reconcile The appropriate Director reviews the request and supporting documentation for accuracy, allowability, and budget compliance. Jitasa reconciles the requested amount to the applicable QuickBooks general ledger accounts and supporting documentation. Any discrepancy shall be resolved and documented before submission. 3. Approve and Submit The appropriate Director provides documented approval through an approved electronic signature platform. By approving the request, the Director confirms that the request has been reviewed for accuracy, allowable costs, appropriate grant allocation, and compliance with the applicable grant budget and funding requirements. Once approved, the Finance & Grants Manager submits the request to the funder or partner with all required supporting documentation. 4. Retain Records The reimbursement request, supporting documentation, electronic approval, and submitted request are retained in the designated grant records in accordance with Section 10 and applicable funder requirements. The policy therefore establishes a documented supervisory approval and reconciliation process before Federal reimbursement or cash draw requests are submitted. Action Plan: JCWC will finalize and present the Fiscal Policy Manual to the Board for formal adoption and will continue implementing the procedures in the interim. The Finance & Grants Manager will work with program staff and Jitasa to prepare and verify Federal reimbursement and cash draw requests. Requests will be reconciled to the QuickBooks general ledger and supporting documentation, with any discrepancies resolved and documented before submission. The appropriate Director will review and approve each Federal reimbursement or cash draw request prior to submission. JCWC will retain the request, supporting documentation, reconciliation, and approval in accordance with its records retention requirements and applicable Federal requirements. Following Board The appropriate Director will review and approve each Federal reimbursement or cash draw request prior to submission. JCWC will retain the request, supporting documentation, reconciliation, and approval in accordance with its records retention requirements and applicable Federal requirements. Following Board

Categories

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

Other Findings in this Audit

  • 1240640 2025-001
    Material Weakness Repeat
  • 1240641 2025-002
    Material Weakness Repeat
  • 1240642 2025-003
    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