Finding 392303 (2022-001)

Significant Deficiency
Requirement
AH
Questioned Costs
-
Year
2022
Accepted
2024-04-04

AI Summary

  • Core Issue: Orlando Shakespeare Theater, Inc. failed to provide documentation for 8 out of 60 transactions, risking noncompliance with federal award requirements.
  • Impacted Requirements: This situation violates 2 CFR sections 200.303 and 200.403, which mandate proper internal controls and documentation for allowable costs.
  • Recommended Follow-Up: Establish formal policies and internal controls for managing expenditures and ensure all supporting documentation is maintained to comply with grant conditions.

Finding Text

Criteria: 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards 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 awards. In addition, 2 CFR section 200.403 requires that costs be adequately documented, among other criteria, to be allowable under federal awards. Condition: For 8 of 60 transactions tested, Orlando Shakespeare Theater, Inc. (the “Organization”) was unable to provide supporting documentation evidencing that the expenditure was incurred, allowable and within the period of performance of the Organization’s Shuttered Venue Operators Grant. The sample was not intended to be, and was not, a statistically valid sample. Cause: The inability to maintain appropriate supporting documentation was due to employee turnover during the pandemic and a lack of formal policies and procedures over expenditures incurred during a previously unforeseen time of remote working during the COVID-19 global pandemic. Effect or Potential Effect: Certain costs incurred by the Organization may be unallowable or outside the period of performance of the grant resulting in noncompliance and possible questioned costs. Recommendation: We recommend that the Organization implement policies, processes and internal controls surrounding expenditures and validate that adequate supporting documentation, including invoices and payment support, is maintained by the Organization to support compliance with grant requirements.

Corrective Action Plan

At the onset of the pandemic, certain employees were sent to work remotely. During this period of time, the Organization experienced larger than usual turnover, including the CFO position, which remained unfilled for a significant period of time. Due to these factors, many employees were forced to handle new responsibilities for the first time in a new remote setting, as the Organization worked diligently to continue operations. Since many of the shows were being cancelled or modified from their traditional format, smaller projects related to design buildout, maintenance, and advertising were taken on. Many of these projects involved smaller retail purchases for which documentation was not properly retained. The Organization acknowledges the findings and has since hired a new CFO and instituted policies and procedures surrounding documentation of all cash disbursements and expenditures of federal awards.

Categories

Period of Performance Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 968745 2022-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
59.075 Shuttered Venue Operators Grant Program $1.09M