Finding 2658 (2022-002)

Significant Deficiency
Requirement
GH
Questioned Costs
-
Year
2022
Accepted
2023-11-28
Audit: 4480
Organization: Ruby's Place (CA)

AI Summary

  • Core Issue: Inadequate documentation and controls over expenditures in the Continuum of Care and Services for Trafficking Victims programs.
  • Impacted Requirements: Compliance with Uniform Guidance section 200.302 on financial management and accurate accounting of federal expenditures.
  • Recommended Follow-Up: Implement a self-monitoring process for controls and ensure Executive Director's expenditures are approved by finance committee members or relevant program managers.

Finding Text

Finding 2022-002; Assistance Listing Number; 14.267, 16.320; Program Title - Continuum of Care Program; Services for Trafficking Victims; Federal Agency - U.S. Department of Housing and Urban Development; U.S. Department of Justice; Criteria - Uniform Guidance section 200.302 Financial Management requires non-federal entities to maintain accurate accounting of federal expenditures within its accounts, and to provide adequate controls over those expenditures.; Condition - Our test of controls over expenditures of non-payroll transactions identified nine of thirty and eleven of thirty transactions in Continuum of Care Program and Services for Trafficking Victims program, respectively, that did not include sufficient documentation of controls over allocation of costs. Errors included unapproved purchase orders, self-approved purchase orders, and expenditures without documentation of approval for the expenditure or allocation.; Cause - The Organization is experiencing challenges in transitioning to a hybrid remote office structure and turnover in the Organization.; Context - Expenditures were supported by receipts and invoices without exception. Expenditures without sufficient documentation of controls over allocation of costs appeared to be reasonable costs for programmatic activities.; Effect - Without consistent application of control processes, deviations that may be fraud will be difficult to differentiate from legitimate transactions, such as purchases for program participant day to day living expenses and gift cards.; Questioned Costs - None.; Prior Audit Finding - No.; Recommendation - The Organization should adopt a self-monitoring process to verify that documented controls are being consistently followed. The Executive Director’s expenditures should be approved by a member of the finance committee, or a relevant program manager if the cost is for a budgeted program expenditure.; Views of Responsible Officials - The Organization agrees with the finding, and will perform procedures to implement the recommendation.

Corrective Action Plan

The Organization will implement a corrective action plan to make sure there are proper internal controls with regards to expenditures. The policy will be updated with guidelines for the approval process. Program managers will be responsible for managing and approving expenditure for programs. Automated bill pay systems like Bill.com have been implemented for documenting the approvals of expenditures. Expected completion and implementation of the purchasing policy: December 2023.

Categories

Procurement, Suspension & Debarment Subrecipient Monitoring Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 2657 2022-001
    Significant Deficiency
  • 2659 2022-002
    Significant Deficiency
  • 2660 2022-002
    Significant Deficiency
  • 579099 2022-001
    Significant Deficiency
  • 579100 2022-002
    Significant Deficiency
  • 579101 2022-002
    Significant Deficiency
  • 579102 2022-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
14.267 Continuum of Care Program $822,532
16.320 Services for Trafficking Victims $441,190
93.327 Demonstration Grants for Domestic Victims of Severe Forms of Human Trafficking $395,005
16.575 Crime Victim Assistance $141,375
16.528 Enhanced Training and Services to End Violence and Abuse of Women Later in Life $129,264
93.623 Basic Center Grant $105,153
16.736 Transitional Housing Assistance for Victims of Domestic Violence, Dating Violence, Stalking, Or Sexual Assault $84,923
93.778 Medical Assistance Program $45,649
93.671 Family Violence Prevention and Services/domestic Violence Shelter and Supportive Services $43,915
14.218 Community Development Block Grants/entitlement Grants $30,993
93.598 Services to Victims of A Severe Form of Trafficking $11,327
97.024 Emergency Food and Shelter National Board Program $8,056
14.235 Supportive Housing Program $8,034