Finding 396710 (2022-003)

Material Weakness
Requirement
B
Questioned Costs
$1
Year
2022
Accepted
2024-05-15
Audit: 306345
Organization: Point of Freedom (OH)

AI Summary

  • Core Issue: Lack of effective internal controls and documentation for contractor expenditures related to federal awards.
  • Impacted Requirements: Noncompliance with Section 200.303 of the Uniform Guidance and 2 CFR Part 200 subpart E regarding cost principles.
  • Recommended Follow-Up: Management should implement internal control procedures to ensure proper documentation and compliance with federal requirements.

Finding Text

According to Section 200.303 of the Uniform Guidance, a nonfederal entity must 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. Point of Freedom receiving Federal Awards must follow 2 CFR Part 200 subpart E, which outlines cost principles in the Uniform Guidance. Adequate documentation is crucial for costs to be allowable under Federal Awards, ensuring compliance, transparency, and accountability in fund utilization. We noted the following matters during testing: 1) Nineteen (19) contractor expenditures have no internal control evidence of timesheet reviewed and approved for the hours charged to the federal program. 2) Seven (7) disbursements have inadequate documentation. There is no formal monitoring over the contractors’ charged hours to the federal program and established policies over maintaining an adequate documentation. This suggests control deficiency over compliance. Incomplete documentation creates a challenge in promptly verifying the accuracy, thereby posing a risk of improper disbursements of federal funds. Of the 693 disbursements, we examined 68 of which seven (7) were identified with incomplete documentation, nineteen (19) contractor invoices without supporting timesheets. In accordance with 2 CFR 200.516(a)(3), auditors are required to report known questioned costs when likely questioned costs are greater than $25,000. Although the sample uncovered 26 transactions with incomplete documentation, resulting in $11,307 in questioned costs, extending the tests to the entire population projects questioned costs exceeding $25,000, specifically $27,462. We recommend that management should develop internal control procedures to address the compliance requirements of federal programs, especially over retaining adequate documentation of transactions.

Corrective Action Plan

As more fully described above, additional internal control procedures and practices will be implemented effective July 1, 2024, to ensure that underlying cost documentation is adequate, reasonable, and complete in accordance with 2 CFR and other regulatory requirements. More specifically, vendor invoices and the like will be scanned and electronically saved on QBO, as incurred. On the other hand, contractors were engaged to perform certain tasks and were not constrained by hours. If the subject service required on-site intervention by the contractor with a POF client at 3 AM, then the contractor was expected to and had agreed to deliver. The contractor would report any such encounters at the subsequent weekly meetings with certain contractors present. Consistent with IRS employer guidelines, POF did not supervise contractors or dictate work habits or work schedules. Instead, POF defined what each contractor was expected to do or deliver. It was incumbent upon the contractor to determine how best to accomplish the assigned and agreed upon duties defined in their jointly signed agreement. POF’s contractors were and are professionals with state credentials, degrees, or certifications which permit them to serve other NPOs or customers as independent contractors. In many cases, their work products were summarized during the previously mentioned POF weekly meetings and transmitted to Wright State University (now the Ohio State University) where the data were aggregated independently by these contracted third parties and made available to POF’s funders. Effective July 1, 2024, copies pf these weekly report summaries will be routinely saved to provide further evidence of POF’s monitoring of contractors’ activities and adherence to contract terms.

Categories

Questioned Costs Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Subrecipient Monitoring

Other Findings in this Audit

  • 396711 2022-004
    Material Weakness
  • 973152 2022-003
    Material Weakness
  • 973153 2022-004
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
93.788 Opioid Str $49,886