Finding 400377 (2023-002)

Finding 2023-002 Significant deficiency in internal control over compliance for special tests and provisions. Federal Agency: Corporation for National and Community Service Pass-Through: Office of Financial Management Program Title: AmeriCorps State and National Assistance Listing Number: 94.006 Award Number: 19FXHWA0020005, Contract No. K3503 Award Period: August 1, 2021 – July 31, 2022 Criteria Internal controls requirements contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, Subpart D ‐ Post Federal Award Requirements, Section 200.303, Internal Controls, require that a non‐Federal 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. 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 for Evaluation The Organization’s internal controls require management of the program to keep ongoing records for each person enrolled in the program. Maximum stipend amounts are determined and set forth by the national Americorps program, and Americorps program staff update the member service agreements (MSAs) when updates are obtained. Of the 15 employees we tested for signed MSAs, 2 did not have MSAs on file and 3 had MSAs signed by the employees but not signed by the Organization’s management. Cause The Organization’s internal controls related to enrolling participants in the program and reviewing that signed MSAs were on file was not consistently applied. Effect or Potential Effect Deficiencies in internal controls related to member service agreements could result in material noncompliance. Questioned Costs None. Repeat Finding Yes. 2022-002 Recommendation We recommend the Organization enforce its policies for retention and review of records for each person enrolled in the program.Views of Responsible Officials and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.