Finding 22514 (2022-003)

Material Weakness
Requirement
ABH
Questioned Costs
-
Year
2022
Accepted
2023-06-28
Audit: 23655
Organization: Heard Museum (AZ)
Auditor: Eide Bailly LLP

AI Summary

  • Core Issue: The Organization lacks proper documentation for the review and approval of expenditures, which violates compliance requirements.
  • Impacted Requirements: This finding relates to 2 CFR 200.303(a), which mandates effective internal controls over federal awards.
  • Recommended Follow-Up: Management should establish a documented approval process for expenditures to maintain an adequate audit trail.

Finding Text

2022-003 Small Business Administration Financial Assistance Listing #59.075 COVID-19 Shuttered Venue Operators Grant Program; SBAHQ21SV007152, July 10, 2021 to December 31, 2021 Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance Material Weakness in Internal Control over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the Organization is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Condition: While the Organization had policies and procedures in place over the review and approval of expenditures, during the testing of expenditures there were certain items that lacked the documentation of such review and approval. The Organization did not retain the required documentation to support the review of expenditures. Cause: The Organization had turnover and limited staffing available. The review and approval process was a collaborative process that took place in face to face meetings without documentation retained. Effect: Lack of documented controls can result in expenditures that are otherwise not an allowable cost or allowable activity. Questioned Costs: None reported Context/Sampling: A nonstatistical sample of 60 transactions out of 1,042 total transactions were selected for testing, which accounted for $108,778 of $1,276,757 of federal program expenditures. Repeat Finding from Prior Year(s): No Recommendation: We recommend the Organization?s management implement a process that allows for documented approval of expenditures to ensure that the audit trail is retained for such expenditures. Views of Responsible Officials: Management agrees with the finding.

Corrective Action Plan

2022-003 Small Business Administration Financial Assistance Listing #59.075 COVID-19 Shuttered Venue Operators Grant Program Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance Material Weakness in Internal Control over Compliance Condition: While the Organization had policies and procedures in place over the review and approval of expenditures, during the testing of expenditures there were certain items that lacked the documentation of such review and approval. The Organization did not retain the required documentation to support the review of expenditures. Cause: The Organization had turnover and limited staffing available. The review and approval process was a collaborative process that took place in face to face meetings without documentation retained. Management?s Response and Corrective Action Plan: The Museum Deputy Directory/COO reviewed all grant expenditures in detail for accuracy and approved them before submission to the SBA, and written documentation of the review and approval of the submitted expenditures was maintained. However, written documentation of the approval of certain expenditures at the time they were actually incurred was not maintained, even though there were consistent, contemporaneous oral communications between the Deputy Director/COO, the Controller and the Payroll Administrator regarding those expenditures. As of January 2023, the CFO has implemented procedures whereby written documentation of approval of those expenditures is maintained. Responsible Individual: Robin Klung, CFO Anticipated Completion Date: January 2023

Categories

Allowable Costs / Cost Principles Material Weakness Period of Performance

Other Findings in this Audit

  • 22515 2022-004
    Significant Deficiency
  • 598956 2022-003
    Material Weakness
  • 598957 2022-004
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
59.075 Shuttered Venue Operators Grant Program $1.28M
59.008 Disaster Assistance Loans $150,000