FAC Explorer

Finding 389520 (2023-001)

Significant Deficiency
Requirement
M
Questioned Costs
$1
Year
2023
Accepted
2024-03-29
Audit: 300483
Organization: The Tor Project, Inc. (WA)
Auditor: Cohnreznick LLP

AI Summary

  • Core Issue: The Agency failed to adequately monitor subrecipients, risking non-compliance with federal regulations and subaward terms.
  • Impacted Requirements: Compliance with 2 CFR 200.332 regarding authorized use and performance goals of subawards was not fully met.
  • Recommended Follow-Up: Management should enhance internal controls and ensure timely monitoring of subrecipients moving forward.

Finding Text

Item #2023-001 Subrecipient Monitoring International Programs to Support Democracy Human Rights and Labor – 19.345 Criteria: Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved per 2 CFR 200.332. Condition and Context: The Agency did not fully monitor the subrecipients to ensure the subaward was used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Cause: Management did not have internal control over subrecipient monitoring to fully address requirements under 2 CFR 200.332 Effect or Potential Effect: The Agency did not timely monitor the subrecipients in a timely fashion. Subsequent to year end the Agency retroactively monitored these activities and determined that one of the four subrecipients did not fully comply with required documentation and determined that $23,134 of costs billed to the contract were not allowable. Questioned Costs: N/A Repeat Finding: No Recommendation: Management should continue to monitor the internal controls established as part of their subsequent to year end activities to ensure all compliance requirements are conducted in a timely manner. Views of Responsible Officials: Subsequent to year end, the Agency implemented internal controls over subrecipient monitoring and retroactively performed these compliance procedures.

Corrective Action Plan

CORRECTIVE ACTION PLAN February 15, 2024 The Tor Project, Inc. (the Organization) respectfully submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent accounting firm: CohnReznick LLP 350 Granite Street, Suite 1200 Braintree, MA 02184 Audit period: July 1, 2022 – June 30, 2023 The findings from the June 30, 2023 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Federal Award Findings and Questioned Costs Significant Deficiency Item #2023-001 - Subrecipient Monitoring International Programs to Support Democracy Human Rights and Labor – 19.345 Issue: The Organization did not fully monitor the subrecipients to ensure the subaward was used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Recommendation: Management should monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved per 2 CFR 200.332. Action Taken: Subsequent to fiscal year end, the Agency implemented additional internal controls over subrecipient monitoring and retroactively performed these compliance procedures. The Tor Project, Inc. sampled monthly invoice periods for each active sub-recipient, per grant, in the period of the FY23 annual external audit. The Tor Project reviewed all supporting documentation for the cost reimbursements of the sample to ensure accuracy and completeness of all reimbursed costs. For all sub-recipients, The Tor Project performed the internal audit procedure selecting a sample of monthly invoices at random per sub-recipient, per grant, per year to verify the completeness and accuracy of all reimbursed costs. If there are any questions regarding this plan, please call Susan Abt at 781-307-8651.

Categories

Questioned Costs Subrecipient Monitoring

Other Findings in this Audit

  • 965962 2023-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
19.345 International Programs to Support Democracy, Human Rights and Labor $287,163
47.070 Computer and Information Science and Engineering $62,583