Finding 395975 (2023-001)

Material Weakness Repeat Finding
Requirement
P
Questioned Costs
-
Year
2023
Accepted
2024-05-06

AI Summary

  • Core Issue: The auditee failed to finalize the SEFA before the audit began, leading to an overstatement of expenditures by $173,389.
  • Impacted Requirements: This situation resulted in non-compliance with the Uniform Guidance for SEFA preparation.
  • Recommended Follow-Up: Review all contracts before fiscal year-end and start SEFA preparation immediately after the fiscal year to ensure accuracy and compliance.

Finding Text

Criteria: In accordance with the Uniform Guidance, 2 CFR 200.510(b), the auditee must prepare the schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements. Condition: The auditee did not finalize the schedule of expenditures of federal awards prior to signing the engagement letter and the start of the audit procedures for the fiscal year July 1, 2022 to June 30, 2023. Additionally, the prepared SEFA included totals representing contractor payments to Florence Crittenton (FCFS), which overstated SEFA total expenditures by $173,389. Context: Initially, the auditee stated that a single audit was not needed for fiscal year 2022-23, and that expenditures of federal awards was below $750,000. The audit engagement letter was prepared and signed, which excluded single audit language. During the course of the audit procedures, the SEFA was prepared by the auditee with the assistance of the auditor, and it was determined that the auditee incurred $816,420 in expenditures of federal awards in fiscal year covering July 1, 2022 to June 30, 2023. Upon the discovery that a single audit was needed for the testing period, the engagement letter was revised, and single audit procedures were completed. During the course of audit procedures for the Single Audit, it was discovered that the state of Montana considered Florence Crittenton to be a non-subrecipient for the stabilization grants under the Child Care and Development Block Grant. Effect: Non-compliance with the Uniform Guidance regarding SEFA preparation. Questioned Costs: There were no questioned costs identified. Cause: Florence Crittenton was not aware that federal expenditures for the fiscal year July 1, 2022 to June 30, 2023 were over $750,000 until the auditor requested documentation that federal expenditures were under $750,000. Recommendation: We recommend the organization review all contracts before the end of the fiscal year to ensure all funds received have the appropriate contracts from state and federal awarding entities, and that the organization begin SEFA preparation immediately following the end of the fiscal year to ensure it includes all federal funds expended and is completed prior to the start of audit procedures. Organization Response: Based on the way that the State of Montana has historically written their grant contracts, it has been difficult to decipher if the organization is a subrecipient or a contractor of the state. This was especially true for any contracts funded through Covid-19 CARES and ARPA funds. Additionally, FCFS was unclear if seed funds from the Innovation grant were considered expended or not. This confusion led to a mistake on the initial SEFA worksheet that indicated federal funds fell below $750,000. Upon further examination by all parties, it was determined that FCFS had in fact expended over $750,000 in federal funds. FCFS immediately signed an engagement letter for Douglas Wilson to complete the SEFA and has since complied with all testing requirements. To ensure this mistake does not happen again, FCFS designed a corrective action plan that will include confirming subrecipient or contractor status with all contracting agencies. This has already been completed with current contracts for FY24. FCFS has subsequently established additional measures to ensure complete review of all contracts and quarterly reporting of all grant spending, regardless of if it is a federal, state, or private grant.

Corrective Action Plan

1. Upon receipt of all grants, FCFS will confirm with the awarding agency the status of subrecipient versus non-subrecipient to determine inclusion in the Schedule of Expenditures of Federal Awards (SEFA). Person Responsible: Carrie Krepps, Executive Director or Sarah Johnson, Operations Director. Timeline for Completion: All current contracts for FY24 have been reviewed; new contracts will be reviewed upon receipt 2. FCFS will prepare quarterly reports for the board detailing grant spend down for both restricted and nonrestricted funding. Person Responsible: Bridget Rebo, Fiscal Officer; Sarah Johnson, Operations Director; FCFS Board. Timeline for Completion: To begin April 23, 2024, board meeting 3. Grant invoicing will be prepared by the Fiscal Officer and reviewed by the Operations Director prior to submission. Person Responsible: Bridget Rebo, Fiscal Officer; Sarah Johnson, Operations. Timeline for Completion: August 2023 4. FCFS will submit to quarterly fiscal review by a 3rd party accounting firm to identify potential weakness in fiscal protocol. Person Responsible: Bridget Rebo, Fiscal Officer; Sarah Johnson, Operations; Pinion Accounting Services. Timeline for Completion: July 2024 for quarterlies ending June 30, 2024. 5. FCFS will employ a 3rd-party accounting firm to help in audit preparation and closing year-end books, including SEFA preparation before submitting any financial documentation to the auditor. Person Responsible: Bridget Rebo, Fiscal Officer; Sarah Johnson, Operations; Pinion Accounting Services. Timeline for Completion: Pinion has signed letter of engagement and will begin on yearend closeout assistance July 2024

Categories

Reporting

Other Findings in this Audit

  • 395976 2023-002
    Material Weakness
  • 395977 2023-001
    Material Weakness Repeat
  • 972417 2023-001
    Material Weakness Repeat
  • 972418 2023-002
    Material Weakness
  • 972419 2023-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.575 Child Care and Development Block Grant $297,001
93.870 Maternal, Infant and Early Childhood Home Visiting Grant $183,018
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $135,304
16.575 Crime Victim Assistance $130,416
93.959 Block Grants for Prevention and Treatment of Substance Abuse $70,681