Finding 2141 (2023-001)

Significant Deficiency
Requirement
AB
Questioned Costs
-
Year
2023
Accepted
2023-11-20
Audit: 3715
Organization: Real Escape From the Sex Trade (WA)
Auditor: Larson Gross

AI Summary

  • Core Issue: There is a significant deficiency in internal controls over non-payroll disbursements, specifically regarding the lack of documented management approval for transactions.
  • Impacted Requirements: Compliance with federal regulations requires that all costs charged to federal awards be allowable, supported by appropriate documentation, and properly approved.
  • Recommended Follow-Up: Implement a review process for all non-payroll disbursement transactions to ensure proper approval and maintain supporting documentation, particularly for ACH payments.

Finding Text

2023‐001: Allowable Costs and Allowable Activities – Internal Controls Over Non‐Payroll Disbursements – Significant Deficiency Criteria: Federal award recipients must establish internal control procedures over compliance with provisions of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) that require, among other things, that direct charges to federal awards be for allowable costs. To be an allowable cost, charges must be supported by appropriate documentation and be properly approved. The specific requirements for allowable activities are unique to each Federal Program and are found in the law, regulations, and the provisions for each contract or grant agreement pertaining to the federal program. Condition and Context: As part of our tests of internal controls over compliance, we selected a sample of forty (40) non‐payroll disbursement transactions to test controls of disbursement costs charged to the major program. The items selected in this sample were also used as a dual‐purpose test for purposes of testing compliance. In our control sample, we noted there was no evidence of management approval prior to the purchase for one (1) of the forty (40) transactions tested. In this instance, the payment was made via ACH but no documentation to evidence the approval was maintained other than reliance on the bank’s automated system which will not execute an ACH without double approval. Questioned Costs: None. Cause: The primary factor that contributed to the deficiency was the lack of sufficient controls implemented to retain supporting documentation for ACH payments. To strengthen internal controls over disbursements, it is recommended that appropriate support be maintained for all disbursements, including ACH payments. Repeat Finding: This finding is not a repeat finding. Effect: Non‐payroll disbursement transactions were being processed without retaining evidence of approval. Auditor’s Recommendation: In order to ensure non‐payroll disbursement transactions are properly reviewed, approved, and supporting documentation maintained, we recommend Real Escape from the Sex Trade ensure controls over these transactions are operating effectively. This control can be accomplished by implementing a review process over each transaction prior to the purchase and formally documenting the approval. Management’s Response: Management agrees with the finding and has prepared correction action as detailed in its Corrective Action Plan.

Categories

Allowable Costs / Cost Principles Procurement, Suspension & Debarment Significant Deficiency

Other Findings in this Audit

  • 2135 2023-001
    Significant Deficiency
  • 2136 2023-001
    Significant Deficiency
  • 2137 2023-001
    Significant Deficiency
  • 2138 2023-001
    Significant Deficiency
  • 2139 2023-001
    Significant Deficiency
  • 2140 2023-001
    Significant Deficiency
  • 2142 2023-001
    Significant Deficiency
  • 578577 2023-001
    Significant Deficiency
  • 578578 2023-001
    Significant Deficiency
  • 578579 2023-001
    Significant Deficiency
  • 578580 2023-001
    Significant Deficiency
  • 578581 2023-001
    Significant Deficiency
  • 578582 2023-001
    Significant Deficiency
  • 578583 2023-001
    Significant Deficiency
  • 578584 2023-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
16.575 Crime Victim Assistance $171,296
21.027 Coronavirus State and Local Fiscal Recovery Funds $11,500
16.588 Violence Against Women Formula Grants $6,511
16.320 Services for Trafficking Victims $1,194