Finding 382825 (2023-001)

Significant Deficiency Repeat Finding
Requirement
P
Questioned Costs
-
Year
2023
Accepted
2024-03-21
Audit: 296427
Organization: Delta Sigma Theta Sorority Inc. (DC)
Auditor: Sb & Company LLC

AI Summary

  • Core Issue: Significant deficiencies in financial reporting due to inadequate documentation for credit card transactions.
  • Impacted Requirements: Internal controls over financial reporting were not maintained, leading to unauthorized purchases and lack of valid business purpose.
  • Recommended Follow-Up: Enforce the credit card policy consistently and consider electronic tracking for purchases, approvals, and receipts.

Finding Text

Reference Number: 2023-001 Federal Program: All Programs Type of Finding: Significant Deficiency over Financial Reporting Repeat Finding: Yes – 2022-001 Criteria Entities should maintain an adequate system of internal controls over financial reporting in order to initiate, authorize, record, process, and report financial data reliably in accordance with accounting principles generally accepted in the United States of America. Condition In fiscal year 2022, our credit card transaction testing resulted in the following findings: (1) 17 out of 25 credit card sections did not have documentation of a valid business purpose; (2) 6 out of 25 credit card selections did not have vendor receipts; and (3) 15 out of 25 credit card selections had no evidence of approval. Based on our discussions with management, the new credit card policy was not fully implemented in fiscal year 2023 and management acknowledged that exceptions to the credit card policy still existed during fiscal year 2023. As such, we did not perform additional testing during fiscal year 2023, and this finding remains as previously documented. Cause Management did not consistently follow its formal credit card policy in place during all of fiscal year 2023 to document requirements for credit card usage and retention of supporting documents for credit card transactions (i.e. vendor invoices, approval of expenditures, proof of valid business purpose, etc.). Effect A fraud risk exists that credit card purchases are unauthorized and are not used for valid business purposes. Questioned Costs Unknown Recommendation Management should enforce its formal credit card policy through-out the year. Management should also consider electronic methods to track credit card purchases, approvals, and receipts. The Grand Chapter should maintain all credit card receipts with business purpose documentation. Management Response and Corrective Action Plan Management agrees with the finding. See schedule of corrective actions.

Corrective Action Plan

The Board approved a new Credit Card Policy of the Sorority in May 2021. Credit cards are an integral part of the mix of instruments available for managing payment relationships with vendors. At present, the Sorority maintains six (6) sponsored credit cards and we recognize and acknowledge that a material risk of exposure is present. While Delta Sigma Theta has a formal credit card policy in place, it has not been consistently following to ensure that assets of the organization are safeguarded. We are implementing a number of new processes and procedures to ensure that future credut card expenditures are documented with the following: 1. Valid business purpose; 2. Vendor receipts included as documentation and support, and; 3. Evidence of proper approval. This will ensure tht the credit card expenses are properly accounted for and reconciled within the general ledger. To achieve the stated objectives, the finance and accounting department has begun implementing a number of internal controls. Payment processes and procedures are being developed for transactions beginning January 1, 2024. They are as follows: 1. Develop a Credit Card Expense Request document that must be completed by those requesting expenditures that includes and discusses the business prupose of the expense. 2. Continuous training with those charged with making purchases with credit cards and those completing reports on the how to utilize the reports developed, how to properly code items to the general ledger and the documentation needed to substantiate the request. 3. New hirings, including new CFO and Director, that started in 2023. Restructuring the team to include higher level accounting staff that have greater education and experience with GAAP accounting. 4. Enforcement by management of its formal credit card policy throughout the year. 5. Monthly reconciliations that highlight compliance and allows for timely enforcement and correction of non-compliance.

Categories

Procurement, Suspension & Debarment Reporting Significant Deficiency Internal Control / Segregation of Duties

Other Findings in this Audit

  • 959267 2023-001
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
84.066 Trio_educational Opportunity Centers $1.05M