Finding 370205 (2022-005)

Material Weakness
Requirement
ABH
Questioned Costs
$1
Year
2022
Accepted
2024-02-22
Audit: 291780
Organization: Africatown Community Land Trust (WA)
Auditor: Brantley Janson

AI Summary

  • Core Issue: The Organization lacks strong document retention policies and internal controls to ensure costs are allowable and related to approved activities.
  • Impacted Requirements: Compliance with 2 CFR section 200.400 regarding the administration of federal funds, including documentation and control systems.
  • Recommended Follow-Up: Provide employee training on cost controls and implement document retention policies to support compliance with federal funding criteria.

Finding Text

"Finding 2022-005 Activities Allowed, Allowable Costs, and Period of Performance – Material Weakness. Criteria: The 2 CFR section 200.400 requires that the Organization must take responsibility for administering the Federal funds in a manner consistent with the underlying agreements, program objectives, and the terms and the conditions of the award. This includes implementing internal controls to ensure that costs are related to activities allowed, the costs are allowable, and the cost are incurred in the period of performance. Condition: The Organization does not have strong document retention policies to demonstrate that costs are for activities allowed, costs are allowable, and incurred in the period of performance. In addition, they did not have systems of controls in place to ensure that expenditures meet the appropriate criteria under Activities Allowed, Allowable Costs, and Period of Performance. The result is that there were several instances in which support for expenditures was not found. In addition, for all transactions that we tested, even though most of the underlying expenditures were allowed, allowable and within the period of performance, there was no system of controls operating at the client to ensure that the costs were consistently appropriate. Cause: The year ended December 31, 2022 was the Organization’s first year receiving federal funding. In addition, there was a lot of turnover in the employees who were involved in processing the transactions related to the award, and a lack of sufficient training. Effect: For 4 selections out of 60 had no available support in the sample that tested activities allowed, allowable costs, and period of performance. The total value of those 4 selections is included in the questioned costs below and these items resulted in the qualified opinion for the Report on Compliance for Each Major Federal Program. Further there were multiple other sample selections that were missing evidence of supervisor approval, had incomplete information, or were inconsistently processed. Questioned Costs: $46,871 of costs that has no available support as described above. Repeat Finding: Not applicable as the Organization is a first time auditee. Recommendation: We recommend that the Organization provide additional training to employees to ensure that controls operate effectively so that only allowable costs are authorized to be charged to the federal awards. Further, we recommend that document retention controls are implemented to support that charges to the federal award are meet the criteria of Activities Allowed and Allowable Costs and Period of Performance. Views of Responsible Official: See Corrective Action Plan."

Corrective Action Plan

Finding 2022-005: Activities Allowed, Allowable Costs, and Period of Performance – Material Weakness. Management Response: We are reviewing our internal controls (SOPs, Operational Manuals and Handbooks), including the document retention policy to assure retrieval. Interdepartmental review of the program contract and the Operations Manual will be held to assure understanding of allowable expenses. 1. Managerial training will be administered to assure Program expenditures are allowable. 2. Operations Manual is being updated to have a process that insures approval workflows for allowable costs. 3. Accounting Policies & Procedures Manual is being updated to improve internal controls & show clear process of compliance over expenditures.

Categories

Questioned Costs Allowable Costs / Cost Principles Material Weakness Period of Performance Internal Control / Segregation of Duties

Other Findings in this Audit

  • 370204 2022-004
    Material Weakness
  • 370206 2022-006
    Material Weakness
  • 370207 2022-007
    Significant Deficiency
  • 370208 2022-008
    Significant Deficiency
  • 946646 2022-004
    Material Weakness
  • 946647 2022-005
    Material Weakness
  • 946648 2022-006
    Material Weakness
  • 946649 2022-007
    Significant Deficiency
  • 946650 2022-008
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $2.19M