Finding 387390 (2023-001)

Significant Deficiency
Requirement
B
Questioned Costs
-
Year
2023
Accepted
2024-03-28
Audit: 299565
Organization: Women in Safe Homes, Inc. (AK)

AI Summary

  • Core Issue: WISH did not keep proper documentation for expenditures, failing to follow its own policies and federal requirements.
  • Impacted Requirements: Internal controls over compliance with federal awards were inadequate, specifically regarding expenditure approvals and documentation.
  • Recommended Follow-Up: Ensure all expenditure documentation is retained and complies with WISH policies and Uniform Guidance to strengthen internal controls.

Finding Text

2023-001 Significant Deficiency in Internal Controls over Compliance - Activities Allowed or Unallowed and Allowable Costs/Cost Principles. IDENTIFICATION OF MAJOR PROGRAM - 93.592 Family Violence Prevention and Services/Discretionary. CRITIERA or SPECIFIC REQUIREMENT - Uniform Guidance 2 C.F.R § 200.303 The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non- Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity's compliance th statutes, regulations and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings. (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, State, local, and tribal laws regarding privacy and responsibility over confidentiality. CONDITION - WISH did not maintain expenditure support and/or evidence of expenditure approvals in accordance with its own policies and procedures. CAUSE - Management was heavily involved in daily operations and receive a significant volume of requisitions so they were often discussed and approved verbally in order to process a check timely within the next check run. EFFECT OR POTENTIAL EFFECT - Lack of substantiation that internal controls are operating effectively in order to allow management, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. QUESTIONED COSTS - None known and likely were below program materiality and questioned costs threshold. CONTEXT - Three credit card expenditures did not have a receipt or invoice to support the charge. For nonpayroll expenditures, a Requisition Form is to be used and contains a line for initiator's signature, supervisor's, and Executive Director's. Auditor noted six instances where the form was either not signed by the Executive Director, or not signed at all. IDENTIFICATION OF REPEAT FINDING - Not Applicable. RECOMMENDATIONS - We recommend that all relevant documentation is retained in order to support approved expenditures and which follow WISH policy and procedures as well as the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS - See corrective action plan

Corrective Action Plan

Federal and State Award Finding: 2023-001 Significant Deficiency in Compliance and Internal ontrols over Compliance - Allowable Costs/Cost Principles Name and Contact Person: Agnes Moran, Executive Director Corrective Action: WISH has evaluated the policies and procedures in place regarding the expenditure approval process, as well as the process for maintaining records supporting all transactions. The policies in place require WISH management to approve all expenditures utilizing a requisition request form which includes a signature field for the initiator, a supervisor, and the Executive Director. WISH management will mandate that all requisition forms are signed (physically or digitally) to ensure compliance with the policy. In order to ensure compliance, WISH will conduct sessions to review the policies with staff and assign a team member to monitor adherence to the policies. Additionally, WISH policies require expenditure support for each transaction including physical and digital receipts and invoices. WISH management will conduct sessions to ensure knowledge of the existing procedures with staff. WISH will assign a team member to review compliance on a monthly basis to ensure compliance. Proposed Completion Date: June 30, 2024

Categories

Allowable Costs / Cost Principles Subrecipient Monitoring Significant Deficiency Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 963832 2023-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.592 Family Violence Prevention and Services/discretionary $574,888
14.228 Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii $443,979
21.027 Coronavirus State and Local Fiscal Recovery Funds $318,646
21.023 Emergency Rental Assistance Program $286,764
16.589 Rural Domestic Violence, Dating Violence, Sexual Assault, and Stalking Assistance Program $182,107
16.888 Consolidated and Technical Assistance Grant Program to Address Children and Youth Experiencing Domestic and Sexual Violence and Engage Men and Boys As Allies $130,845
16.736 Transitional Housing Assistance for Victims of Domestic Violence, Dating Violence, Stalking, Or Sexual Assault $124,477
16.575 Crime Victim Assistance $108,419
16.524 Legal Assistance for Victims $72,422
10.569 Emergency Food Assistance Program (food Commodities) $58,985
14.251 Economic Development Initiative, Community Project Funding $45,756
14.231 Emergency Solutions Grant Program $38,529