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Finding 2022 ? 001 Subject: Coronavirus Relief Funds ? internal controls Federal Agency: Department of the Treasury Federal Programs: Coronavirus State and Local Fiscal Recovery Funds, Coronavirus Relief Fund ALN: 21.019, 21.027 Federal Award numbers and Years (or other identifying numbers): 2020-2021, 2021-2022 Pass-Through Entity: Chicago Bar Foundation Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance Audit finding: Material Weakness Condition An effective internal control system was not in place at the Center for Conflict Resolution in order to ensure compliance with requirements related to the grant agreements and the compliance requirements listed above. Technology expense requested for reimbursement was not actually expended prior to requesting reimbursement in May 2022 in the amount of $95,000. Center for Conflict Resolution recorded the expenditure in May 2022 but did not actually release the check until July 2022 and did not sign the contract until June 2022. Upon identifying the issue, Center for Conflict Resolution was informed, and they reissued a revised May reimbursement request, excluding the held check, and included the expenditure in the July 2022 reimbursement request. The Chicago Bar Foundation is 3 months behind on reimbursements to Center for Conflict Resolution and as such the amount has not been reimbursed as of the date of the audit. Context The lack of internal controls was an isolated issue within the audit period and only affected one expenditure in the last month of the audit period. Criteria `The auditee shall: . . . (b) Maintain internal control over Federal programs that provides reasonable assurance that the auditee is managing Federal awards in compliance with laws, regulations, and the provisions of contracts or grant agreements that could have a material effect on each of its Federal programs. . . ." 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Cause The Center for Conflict Resolution?s management had not developed or implemented an effective system of internal controls to ensure compliance with the grant agreement and the compliance requirements listed above. Effect The failure to establish an effective internal control system placed Center for Conflict Resolution at risk of noncompliance with the grant agreement and the compliance requirements listed above. A lack of internal controls pertaining to the expenditures and reimbursement requests could have allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the Center for Conflict Resolution's management establish controls to ensure compliance with the grant agreement and the Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance compliance requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.