Finding 38596 (2022-001)

Material Weakness
Requirement
ALP
Questioned Costs
-
Year
2022
Accepted
2023-09-28
Audit: 31354
Organization: Nisqually Land Trust (WA)

AI Summary

  • Core Issue: The Trust is not regularly reviewing and reconciling grant arrangements and property purchases, leading to significant accounting errors.
  • Impacted Requirements: This affects compliance with generally accepted accounting principles, resulting in misstatements of grant revenue, assets, and liabilities.
  • Recommended Follow-Up: Establish a formal review process for all grants and contracts, ensuring monthly or quarterly reconciliations, with active participation from both accounting and program staff.

Finding Text

2022-001 GRANT ACCOUNTING Criteria: Generally accepted accounting principles require recording revenue when earned and expenses when incurred. Corresponding receivables and payables, and deferred revenue when applicable, should be reflected in the financial records. Regular review and reconciliation of activities are necessary to ensure accurate and complete financial accounting and reporting. Condition: The Trust performs activities and services under grant contracts with federal and state agencies that are reimbursement type arrangements. In addition, the Trust often has grant and other funds paid directly to title companies on the Trust?s behalf, from grantors and contributors, when property and easement purchases are in process. As expenses for qualifying activities are incurred, contracts should be billed and revenue and receivable recorded. Any grant funds paid directly to escrow from grantors and contributors, along with assets and expenses on purchase transactions, should be recorded in the Trust accounting records when these purchases are completed. While conducting the audit, we determined that the Trust was not reviewing and reconciling grant arrangements on a regular basis and was not reviewing and reconciling all property and easement purchases and recording complete activity. Effect: Lack of a regular review and reconciliation of grant arrangements and contracts resulted in material misstatements of grant revenue, grants and accounts receivable, land assets, liabilities, inkind donations, and easement acquisition expense. In one instance, a property purchase for $1,900,000, for which the Trust received grants and contributions paid by grantors and contributors directly to a title company, was omitted from the accounting records, resulting in a understatement of land assets, grant revenue, and contributions. In another instance, an easement purchase by the Trust, with a $2,240,000 purchase value, was classified as a land asset in error, as Trust accounting policy requires expensing easements in the year of acquisition. This transactions included an in-kind donation from the seller of the easement that was erroneously recorded as grant revenue. The Trust also omitted grant revenue and receivables from the accounting records for amounts earned but not yet received at December 31, 2022, and recorded grant revenue for gamounts received in 2022 that were earned in 2021. Cause: The Trust contracts with an outside company to provide general accounting services. Trust program management and staff are responsible for grant activities performance and billing, while the outside company is responsible for maintaining the accounting records, in coordination with management and staff. Lack of review and reconciliation of all grant and contracts, with participation of the accounting and program individuals, resulted in the omissions and errors noted above. Recommendation: We recommend that the Trust implement a formal review and reconciliation process for all grants and contracts, including all land and easement purchases. This review should be completed on a monthly or quarterly basis, except for property and easement purchases which should be reviewed and reconciled when a purchase closes. Accounting and program personnel should participate in this review and reconciliation, and particular attention should be paid to type of activity being performed, source of all funds received, and proper classification and timing for each, including recording revenue and receivable in the period earned.

Corrective Action Plan

The Nisqually Land Trust agrees with the findings reported and will take corrective actions to rectify the findings. All of the below actions will be in place by October 20, 2023. 2022-001 GRANT ACCOUNTING The financial operating procedures will be revised to reflect an improved level of internal controls and procedures in the finance department, including the following: o Implementation of a monthly procedure for reconciling and reviewing all accounting functions and reporting. o Executive level leadership has been given access to review reports within the accounting software. Notes and reports from monthly review between the Finance and Operations Manager, bookkeeper, and program directors will be provided to the Executive Director for review monthly. o The Finance and Operations Manager position description will be updated to make clear that they have a responsibility to ensure all processes are being followed & to identify training gaps. Monthly self-monitoring is part of the Finance and Operations Manager duties to oversee or delegate as needed. The purpose of the self-monitoring is to spot check various aspects of accounting tasks to ensure processes are being followed and training is provided immediately. ? Reporting on grant activities will be updated and standardized for all programs and for the Nisqually Land Trust in its entirety. This will allow Nisqually Land Trust?s finance processes to be more transparent to program directors and the Board. ? Training plans are being improved and implemented for all finance positions as well as identifying necessary training for program management. o A training plan for each finance position will be developed and initiated in the current year. It will be evaluated annually and updated to stay current with training needs. o The training plans and progress are monitored by the Finance and Operations Manager and the Executive Director. o Nisqually Land Trust will continue to prioritize budgeting for training of fiscal staff

Categories

Procurement, Suspension & Debarment Cash Management Reporting Internal Control / Segregation of Duties

Other Findings in this Audit

  • 38597 2022-002
    Material Weakness
  • 38598 2022-003
    Material Weakness
  • 615038 2022-001
    Material Weakness
  • 615039 2022-002
    Material Weakness
  • 615040 2022-003
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
15.614 Coastal Wetlands Planning, Protection and Restoration Program $1.87M
11.438 Pacific Coast Salmon Recovery_pacific Salmon Treaty Program $202,173
10.912 Environmental Quality Incentives Program $21,513
15.630 Coastal Program $13,143