Finding 395031 (2023-005)

Material Weakness
Requirement
P
Questioned Costs
-
Year
2023
Accepted
2024-04-29
Audit: 304969

AI Summary

  • Core Issue: The organization lacks effective internal controls over federal awards, leading to noncompliance with federal standards.
  • Impacted Requirements: Failure to document and approve payroll and non-payroll disbursements as required by 2 CFR 200.303 and internal control frameworks.
  • Recommended Follow-Up: Strengthen policies and procedures for disbursement and allocation processes to ensure proper documentation and approval.

Finding Text

Finding 2023-005 – Internal Controls over Federal Awards (Material Weakness and Noncompliance) Information on the Federal Program: U.S. Department of Justice, Assistance Listing No.16.575 Victims of Crime Act (VOCA) Criteria: 2 CFR 200.303 requires non-federal entities to establish and maintain effective 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 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). Condition/Context: We selected 50 disbursements for testing. Of those 50, 25 were for payroll and 25 were non-payroll disbursements. Of the 25 payroll, 2 employees did not have an approved pay rate. Of the 25 non-payroll, 9 of the expenses were allocated to the VOCA grant through a process in the accounting system. 7 out of the 9 allocations were not properly documented as reviewed and approved by management. Of the remaining 14 non-payroll disbursements, 4 lacked documentation of approval for payment. Cause: The Organization did not properly document controls established to review and approve expenses charged to the grant. Effect: The Organization did not comply with internal control compliance standards. Questioned costs: None Recommendation: We recommend the Organization strengthen its policies and procedures surrounding disbursement and allocation processes to document the review and approval process to meet the control standards. Views of Responsible Officials: See Management’s View and Corrective Action Plan included at the end of the report.

Corrective Action Plan

This finding is related to activities on our VOCA grants. As was the case in Finding #004, the majority of the exceptions were related to either finding #2 above or were related to the process in place prior to May 2023. Again, in May 2023 FRLS added an electronic transaction approval process via teams, that documents approvals for all our AP, AR and other transactions initiated by our accounting staff. These are reviewed and approved by the CFO before being posted into the GL. It was also noted that our process of allocating costs from our overhead cost centers to our various grants, was not fully documented. The CFO will undertake a review of this process to ensure that we are in compliance with allowable cost documentation requirements. We will also review and update our documentation of allocations and ensure that each month’s allocation is properly approved. This review will be completed within the next 90 days.

Categories

Allowable Costs / Cost Principles Material Weakness Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 395030 2023-004
    Material Weakness Repeat
  • 395032 2023-006
    Significant Deficiency Repeat
  • 395033 2023-007
    Significant Deficiency Repeat
  • 395034 2023-008
    Significant Deficiency
  • 395035 2023-009
    - Repeat
  • 971472 2023-004
    Material Weakness Repeat
  • 971473 2023-005
    Material Weakness
  • 971474 2023-006
    Significant Deficiency Repeat
  • 971475 2023-007
    Significant Deficiency Repeat
  • 971476 2023-008
    Significant Deficiency
  • 971477 2023-009
    - Repeat

Programs in Audit

ALN Program Name Expenditures
09.020 Legal Services Corporation $7.18M
16.575 Crime Victim Assistance $1.52M
21.008 Low Income Taxpayer Clinics $142,805
21.023 Emergency Rental Assistance Program $85,587
12.599 Congressionally Directed Assistance $62,378
14.231 Emergency Solutions Grant Program $47,405
14.218 Community Development Block Grants/entitlement Grants $13,052
93.052 National Family Caregiver Support, Title Iii, Part E $5,859
93.044 Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers $1,473