Finding 1240645 (2025-006)

Material Weakness Repeat Finding
Requirement
L
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 compliance related to financial reporting for Federal awards.
  • Impacted Requirements: The organization failed to meet 2 CFR 200.303 and 2 CFR 200.302 by not having documented supervisory reviews and relying on external workbooks instead of the accounting system.
  • Recommended Follow-Up: Implement formal internal controls, including documented reviews and using the accounting system for Federal Financial Reports, and develop a written policy for the reporting process.

Finding Text

2025-006 Finding – Federal Award Type: Material Weakness in Internal Control over Compliance – Financial Reporting 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 provide accurate, current, and complete disclosure of the financial results of each Federal award, support the preparation of required financial reports, and maintain records sufficient to demonstrate compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition / Context: The Organization submitted the required Federal Financial Report (FFR) by the applicable deadline. However, the report was prepared and submitted by a single employee without documented supervisory review or approval. In addition, the FFR was prepared using an external workbook rather than being directly supported by the Organization's accounting system or general ledger. As a result, the financial management system was not sufficiently utilized to support the preparation of the required Federal financial report. Cause: The Organization had not implemented procedures requiring documented supervisory review and approval of Federal Financial Reports prior to submission. Additionally, Federal Financial Reports were prepared using information maintained outside of the accounting system rather than being generated or supported directly by the general ledger. Effect: The lack of documented review and reliance on records maintained outside of the accounting system increases the risk that Federal Financial Reports may contain incomplete, inaccurate, or unsupported financial information. Consequently, the Organization may be unable to demonstrate that financial reports submitted to the Federal awarding agency are complete, accurate, and supported by its accounting records. Questioned Costs: None.We recommend the Organization implement formal internal controls over the Federal financial reporting process, including documented supervisory review and approval of all Federal Financial Reports prior to submission. Federal Financial Reports should be prepared using information maintained within the accounting system and reconciled to the general ledger before submission to ensure the reports are complete, accurate, and fully supported. Additionally, management should develop and implement a written Federal financial reporting policy that establishes procedures for preparing, reviewing, approving, reconciling, documenting, and retaining Federal Financial Reports in accordance with the Uniform Guidance. Management’s Response: Management concurs with the finding and will implement effective internal controls over Financial Reporting.

Corrective Action Plan

2025-006 Habitat Conservation – Assistance Lising #11.463 - Material Weakness in Internal Control over Compliance – Financial Reporting Recommendation: We recommend the Organization implement formal internal controls over the Federal financial reporting process, including documented supervisory review and approval of all Federal Financial Reports prior to submission. Federal Financial Reports should be prepared using information maintained within the accounting system and reconciled to the general ledger before submission to ensure the reports are complete, accurate, and fully supported. Additionally, management should develop and implement a written Federal financial reporting policy that establishes procedures for preparing, reviewing, approving, reconciling, documenting, and retaining Federal Financial Reports 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 Federal financial reporting. The revised Fiscal Policy Manual establishes a specific Federal Financial Reporting Process in Section 7.4.1 that defines responsibilities and required controls for preparing, verifying, reconciling, reviewing, approving, submitting, and retaining Federal Financial Reports. The new process requires: 1. Prepare and Verify The Finance & Grants Manager works with Jitasa to prepare Federal Financial Reports using information maintained in QuickBooks and supporting documentation and verifies that reported expenditures are allowable, properly allocated, within the approved budget, and adequately supported. 2. Reconcile and Review Jitasa reconciles reported expenditures to the applicable QuickBooks general ledger accounts and supporting documentation. Any discrepancies must be investigated, corrected, and documented before submission. 3. Review and Approve The Executive Director reviews the Federal Financial Report and supporting documentation for accuracy, completeness, and compliance with Federal award requirements and provides documented approval through an approved electronic signature platform prior to submission. 4. Submit and Retain Following approval, the Finance & Grants Manager submits the report by the applicable deadline and retains the submitted report, supporting documentation, reconciliation, and documented approval in accordance with Section 10 and applicable Federal requirements. Action Plan: JCWC will finalize and present the Fiscal Policy Manual to the Board for formal adoption and will continue implementing the Federal Financial Reporting Process in the interim. Management will use the procedures established in Section 7.4.1 for all applicable Federal Financial Reports and will monitor compliance with the required preparation, reconciliation, review, approval, submission, and record-retention procedures. Any discrepancies or gaps identified through the reporting process will be addressed and documented. Name(s) of the contact people responsible for correction action: Jennifer Hamilton, Executive Director Sean Connolly, Finance & Grants Manager Jitasa Plan completion date for corrective action plan: December 31, 2026 for implementation and monitoring ongoing.

Categories

Reporting

Other Findings in this Audit

  • 1240640 2025-001
    Material Weakness Repeat
  • 1240641 2025-002
    Material Weakness Repeat
  • 1240642 2025-003
    Material Weakness Repeat
  • 1240643 2025-004
    Material Weakness Repeat
  • 1240644 2025-005
    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