Finding 32336 (2022-001)

Significant Deficiency
Requirement
A
Questioned Costs
-
Year
2022
Accepted
2023-03-29

AI Summary

  • Core Issue: Lack of documented approval for bank reconciliations and vendor invoices, leading to potential compliance risks.
  • Impacted Requirements: Non-compliance with 2 CFR Part 200 and AICPA standards regarding internal controls and documentation.
  • Recommended Follow-Up: Implement a system for timely reconciliations and ensure all approvals are documented with initials and dates, or through electronic means.

Finding Text

SECTION 2 ? FINANCIAL STATEMENT FINDINGS Finding 2022-001 Internal Control over Bank Reconciliation and Vendor Invoice Approval Condition: Bank statements and bank reconciliations were prepared and reviewed by two individuals, but the approval was not documented in writing (or electronic means). Invoices were not defaced prior to payment, review by supervisory personnel not documented and program to be changed for the expenditure was not noted on the invoice, and therefore not approved. Cause: The Organization has developed an internal control documentation but has not a prior audit. They were unaware, even in a small office, that documented procedures by initial and dating (manually or electronically) is required as evidence of segregation of approval duties. Criteria: Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Effect: The supervisory personnel approval of the bank statement, bank reconciliation, vendor invoices and charge to program(s) was not documented. Recommendation: Bank statements and bank reconciliations: Bank reconciliations should be prepared within 30 days of the receipt of the statement. Banks may not correct any errors (or fraud) that is not detected and reported within that time frame. The bank statement and bank reconciliation should be reviewed by a person other than the preparer and that person should initial and date (or electronic procedure of comparable nature) as reviewed and approved. The bank reconciliation balance should agree with the general ledger balance(s). Upon approval of vendor invoices, the invoice should be defaced, and the vendor, amount and program charged should be initialed and dated (or electronic procedure of comparable nature), on the face of the invoice, by supervisory personnel. Management?s response: Management agrees with this recommendation and have taken steps to implement proper review and documentation for bank reconciliations and vendor invoice approvals. Person Responsible: President/CEO, Finance Officer, and Program Managers

Corrective Action Plan

CORRECTIVE ACTION PLAN Finding 2022-001 Internal Control over Bank Reconciliation and Vendor Invoice Management Response: Management agrees with this recommendation and have taken steps to implement proper review and documentation for bank reconciliations and vendor invoice approvals. Person Responsible: President/CEO, Finance Officer, and Program Managers Finding 2022-02 Debarred and Suspended Vendors Management Response: Management agrees with this recommendation and have taken steps to develop and implement proper internal controls. Person Responsible: Finance Officer and Program Managers Finding 2022-03 Monitoring Subcontractor Performance Management response: Management agrees with the recommendation and have scheduled training for key personnel. Person Responsible: Program Managers Finding 2022-04 Written Approval of Subcontractors Management Response: Management agrees with this recommendation and have scheduled training for key personnel. Person Responsible: President/CEO and Program Managers Finding 2022-005 Indirect Cost Allocation ? Questioned Costs Management Response: Management agrees with the need for additional grant training, especially as it applies to calculating and allocating indirect costs. However, we do have issues with the classification of expenses within the original contract and hope we can reconcile those prior to the finalization of the grant award. Person Responsible: President/CEO Finance Officer

Categories

Material Weakness Internal Control / Segregation of Duties

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
17.277 Workforce Investment Act (wia) National Emergency Grants $424,000
17.258 Wia Adult Program $205,828