Finding Text
2021-002 – Earmarking, Reporting (Performance Progress Reporting)
Material Weakness in Internal Controls Over Compliance and Instance of Noncompliance (Scope Limitation)
Assistance Listing Number: 16.589
Federal Agency/Pass-through Entity - Program Name: Department of Justice - Rural Domestic Violence, Dating Violence, Sexual Assault, Stalking Assistance Program
Award Number: 2020-WR-AX-0041
Award Year(s): 2020-2023
Criteria or specific requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Grant Agreement Requirements - Earmarking
Section 50 of the grant agreement requires that no more than 30% of project activities and grant funds will be dedicated to awareness and prevention activities.
Grant Agreement Requirements – Performance Progress Reporting
Section 35 of the grant agreement requires submission of semi-annual performance progress reports that describe activities conducted during the reporting period, including program effectiveness measures.
2 CFR Section 200.403(g) states that for costs to be allowed under Federal awards, they must be adequately documented and there must be sufficient documentation.
Lastly, according to 2 CFR 200.1, Period of Performance is defined as the total estimated time interval between the start of an initial Federal award and the planned end date, which may include one or more funded portions, or budget periods.
Condition: The Coalition does not have controls in place to track actual expenditures related to the earmarking requirements in Section 50 of the grant award.
The Coalition does have controls related to the review and approval of performance progress reports; however, it was noted that this control was not operating effectively to ensure proper document retention to support earmarking amounts reported.
Questioned Costs: Questioned costs are not determinable.
Context: We tested one semi-annual performance progress report required by Section 35 of the grant agreement. We noted that the Coalition reported 5% of grant expenditures for awareness and prevention activities, related to the earmarking requirement of Section 50. The Coalition could not provide supporting documentation for the percentage reported. While the percentage reported by the Coalition did not exceed the 30% earmarking threshold, we were unable to obtain sufficient appropriate evidence to support compliance with program earmarking.
Cause: The Coalition did not maintain the supporting documentation for the percentage earmarking reported on semi-annual performance progress report due to change in personnel.
Effect or potential effect: Without proper record retention, the Coalition is unable to support the amounts reported for earmarking percentages on their semi-annual performance progress report, causing potential noncompliance.
Repeat Finding: Yes, 2020-003
Recommendation: We recommend that the Coalition develop policies and procedures for tracking actual expenditures related to earmarking requirements and maintain all supporting documentation for the calculation of the earmarking percentages that are reported in the semi-annual performance progress reports.
Views of responsible officials: The Coalition's staff has developed policies and procedures for tracking actual expenditures related to these requirements, and maintaining all supporting documentation for the calculation of the earmarking percentages that are reported in the semi-annual progress reports. The Coalition has developed an internal control process for reviewing and approving calculations required by Section 50 of the grant agreement and has strengthened its reporting management review controls to ensure that the review is effective to ensure the completeness and accuracy of reports, and that all elements are appropriately supported, prior to submission the federal agency.