Finding 405882 (2023-001)

Material Weakness
Requirement
AB
Questioned Costs
-
Year
2023
Accepted
2024-07-01
Audit: 311449
Organization: Every Woman's Place (MI)

AI Summary

  • Core Issue: The organization lacks proper approval processes for expenditures, leading to potential financial misstatements.
  • Impacted Requirements: This violates Section 200.303 of the Uniform Guidance, which mandates effective internal controls and proper documentation for federal awards.
  • Recommended Follow-Up: Implement a structured approval process where management reviews and documents approval for all invoices to ensure compliance.

Finding Text

Lack of approval for Expenditures (For Financial Statement activity and the Crime Victim Assistance – ALN 16.575 program) Criteria: Criteria: Section 200.303 of the Cost Principles of the Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires a non-Federal entity to establish and maintain effective internal control over the Federal award that provides a 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 the specified guidance that requires proper segregation of duties by dividing key responsibilities among different people to reduce the risk of error or fraud. This should include separating the responsibilities for authorizing transactions, processing and recording them, reviewing the transactions, and handling any related assets. No one individual should control all key aspects of a transaction or event. In addition, this guidance also requires transactions and internal controls to be clearly documented, and the records should be properly maintained and readily available for examination. Condition: The Organization did not have an effective internal control system in place in regard to approving invoices and maintaining documentation. Nine of 40 disbursements tested did not have supporting documentation for the approval by Executive Director. Cause: The Organization did not implement an internal control process over approval of disbursements. Effect: The lack of internal controls could lead to a misstatement of financial and program reports and resulted in noncompliance. Recommendation: The organization should appropriate levels of management all review and approve all invoices and maintain the documentation of approval for each invoice. Management Response: See corrective action plan on pages 29-31.

Corrective Action Plan

EWP has reviewed the current internal control system for financial management and re-implemented the review and approval process for all invoices and expenditures. Program staff are required to obtain pre-approval for expenses and the expenditure must be approved by the Program Supervisor, Program Director, and Executive Director prior to purchase. During the audit period, the agency was moving toward a digital document retention system that had not yet been fully implemented. Currently, the agency has moved back to a paper approval system to ensure that the expense is walked through all levels of approval before purchase. While we do hope to pursue a digital system in the future, obtaining physical signatures for expenses has provide an extra level of internal control for the approval process.

Categories

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

Other Findings in this Audit

  • 405883 2023-002
    Significant Deficiency Repeat
  • 982324 2023-001
    Material Weakness
  • 982325 2023-002
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
16.575 Crime Victim Assistance $664,081
93.558 Temporary Assistance for Needy Families $264,812
14.267 Continuum of Care Program $223,328
93.671 Family Violence Prevention and Services/domestic Violence Shelter and Supportive Services $99,687