Finding Text
Criteria: 2 CFR 200.303(a) requires non-federal entities to establish and maintain effective internal control over the federal award that provides reasonable assurance of compliance with federal statutes, regulations and the terms of the award. Under the PEMA-DAP-9 Request for Reimbursement, the Church certifies that the costs reported were incurred for eligible work, that the work was approved, and that it complied with the terms of the award. Condition: The Church submits reimbursement requests (Form PEMA-DAP-9) to PEMA. We tested 3 requests and agreed each to supporting invoices and to the related deposit. Each request was signed by the Church Treasurer, but there was no evidence that anyone other than the preparer reviewed and approved the request, before it was submitted. Cause: The Church has not established a formal procedure requiring independent review and approval of reimbursement requests prior to submission. Effect: Without an independent review, ineligible, unsupported, or incorrectly calculated costs could be certified to PEMA and FEMA and not be prevented or detected on a timely basis. We did not identify any noncompliance or questioned costs in the requests we tested. Questioned costs: None Recommendation: We recommend that the Church adopt a written procedure requiring a person independent of the preparer to review each reimbursement request and its supporting documentation before submission, and to document the review. Views of responsible officials: The Church agrees with the finding. Going forward, all reimbursement requests will be reviewed and approved by someone independent of the preparer, before submission.