Finding 419329 (2022-001)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
-
Year
2022
Accepted
2023-09-07

AI Summary

  • Core Issue: Internal controls over financial accounting are inadequate, leading to inaccurate financial reporting in accordance with U.S. GAAP.
  • Impacted Requirements: Compliance with Uniform Guidance Section 2 CFR 200.303(a) for effective internal controls over federal awards.
  • Recommended Follow-Up: Implement quarterly financial analytics, review contract terms for proper accounting, provide ASC 958 training, and engage a CPA for quarterly reconciliation reviews.

Finding Text

2022-001 Accounting System, Processes and Reporting Identification as a Repeat Finding: Repeat of Finding 2021-001Finding:Internal control processes over financial accounting did not ensure that all transactions were properly recorded in accordance with U.S. GAAP on a timely basis.Criteria:The Urban League is responsible for day-to-day transactional accounting as well as annual financial statement reporting. As such, the Organization is responsible for implementing adequate procedures to ensure that such information and reports are accurate and complete.Uniform Guidance Section 2 CFR 200.303(a), Internal Controls, requires that non-federal entities must establish and maintain effective internal controls over the federal award that provides reasonable assurance that the non-federal entity is managing the award in compliance with federal statutes, regulations and the terms and conditions of the federal award.Sample Size and Population:Sampling was not applicable to this finding.Condition and Context:The Organization experienced turnover in its accounting and finance department at the beginning of the fiscal year. In the midst of the transition in staffing, historic knowledge of accounting for certain transactions was lost and reconciliations prepared did not use accurate accounting records and lacked clerical accuracy.Effect:Interim financial statements utilized by the Board of Directors for decision making in FY2022 did not accurately reflect the financial condition of the Organization on a U.S. GAAP basis. The Organization?s internal controls failed to identify material errors in accounting including the following:? 18 months of operating activities were recorded within the consolidating Partnership?s accounting records for the 12 month period ended June 30, 2022.? $704,017 in advanced payments of federal funds that were received in the year ended June 30, 2021 were recognized as revenue during that year and were not appropriately reflected as refundable advances as of that date as disclosed in Note 20 of the financial statements.? Material adjustments were identified in the Organization?s accounting for restricted revenue and net assets with donor restrictions.? The Organization's accounting for a fiscal sponsor relationship did not appropriately reflect accounting for such relationships under ASC 958, Not-For-Profit Entities.Cause:The errors identified in the Partnership?s accounting records reflect errors in the design of reconciliations. The errors in accounting for advanced payments of federal funds reflect documentation retention matters addressed in Finding 2021-006. Additionally, the errors in accounting for advanced payments, restricted revenue, and fiscal sponsor relationships reflect errors in identifying the accounting treatment for contract terms.Recommendations:? Perform analytics of financial data at least quarterly to identify unusual activity that may indicate errors in accounting.? Establish a process for reviewing contract terms and evaluating, communicating, and documenting the appropriate accounting treatment.? Obtain training on ASC 958, Not-for-Profit Entities.? Engage a third-party CPA to review accounting reconciliations on a quarterly basis.Questioned Costs: NoneManagement Response and Corrective Action Plan: See Corrective Action PlanContact Person: Mansour Camara, CFO

Corrective Action Plan

ULMS Corrective Action Plan for FY 21-22 Audit FindingsULMS faced significant challenges with the departure of its longtime CFO two months post fiscal year 2021. In addition, the third-party management company who had been responsible for the Partnership accounting, ceased the relationship abruptly without opportunity to smoothly transition the responsibility in-house to ULMS. Our external auditor does not prepare a Management Letter typically used to communicate with the Board of Directors and Governance issues that may not elevate to a finding. As such, significant findings are reflected in Section III ? Federal Award Findings and Questioned Costs.FY 2021 was the organization?s first single audit reporting requirement. ULMS engaged a third-party CPA to review past audit and current documents needed to commence the FY 2022 audit. However, due to an emergency there was limited independent review of documents prior to being submitted to the auditor due to time constraints. ULMS continues to strengthen its accounting team and has hired a new Controller in July 2023. The new Controller is a licensed CPA with over 30 years accounting experience and over 10 years? experience as an independent auditor for a range of organizations including non-profits. The Controller will collaborate with the CFO to ensure there is accuracy in reporting, especially for major federal programs. Finding #: 2022-001Contact Person: Mansour Camara? It is important to note that this error had no impact on the Urban League Village at Coleman School LP?s (?Partnership?) standalone financials or their audit, nor does it affect ULMS?s standalone financials. The error only affects the consolidating financials for the entities, mainly because ULMS and ULV at Colman School LP have different fiscal year periods. The total impact of the additional 6 months of operating activities recorded within the consolidating financials for FY 2022 was less than 1% of operating activities. The error was corrected and not reflected in the audited financial statements for FY 2022.The interim financial statements provided to the Board of Directors during FY 2022 for decision making did not include consolidated financial statements. Interim financial statements provided to the Board only included standalone financial statements. Consequently, there were no inaccurate financial statements provided to the Board for decision making.Actions to be taken: The error in preparing consolidated financials was corrected and not reflected in the audited financial statements for FY 2022. Management will perform quarterly analytics of financial data for the partnership and close its books in alignment with the consolidated financials.Finding #: 2022-001Contact Person: Mansour Camara? The $704,017 was recorded in temp restricted net assets based on a proposed adjusting journal entry from the auditors during FY 2021 audit. $388,728 was refunded to the grantor and should have been recorded as accounts payable at year end FY 2021 and the remainder $304,177 should be classified as deferred revenue as the grantor extended the time period for earning the revenue. $11,112 was earned and the expenses were accrued during the period of performance of the contract in FY 2021 and should not have been included in the auditor?s total of $704,017. The practice of ULMS was to record forward funded contracts in revenue and record an adjustment at year end to temporary restricted funds. Net spendings for each program was communicated to the grantor and appropriate actions taken based on grantor?s instruction. The grantor was informed of the underspent funds prior to the commencement of the audit and management refunded the underspent funds as requested by the funder in compliance with contract terms.It is Management?s position that these Findings should be withdrawn. The longstanding practice of the organization was to record revenue upon receipt of funds and at year end prepare an adjustment to net asset with donor restriction. Consistency in accounting presentation is an essential concept to financial statement preparation. The accounting staff followed the recommendation of the auditor in FY 2021 audit by recording AJE 23. Now the organization is being critiqued in FY 2022 for recording the proposed adjustment and following the recommendation of the auditor.Actions to be taken: The organization?s policy has changed to record all unearned revenue as deferred revenue. ULMS hired a professional CPA with over 10 years? experience in nonprofit auditing as the new Financial Controller.? Management disagrees with auditors? recommendation to impound the funds of Black Lives Matter Seattle King County (BLMSKC) received through the fiscal sponsorship agreement. However, ULMS executed the auditor?s recommendation.Actions to be taken: ULMS will hold the funds of BLMSKC until the organization receives documentation allowing the legal release of the funds.

Categories

Reporting Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 419309 2022-002
    Material Weakness Repeat
  • 419310 2022-004
    Material Weakness
  • 419311 2022-004
    Material Weakness
  • 419312 2022-004
    Material Weakness
  • 419313 2022-004
    Material Weakness
  • 419314 2022-004
    Material Weakness
  • 419315 2022-002
    Material Weakness Repeat
  • 419316 2022-002
    Material Weakness Repeat
  • 419317 2022-004
    Material Weakness
  • 419318 2022-002
    Material Weakness Repeat
  • 419319 2022-004
    Material Weakness
  • 419320 2022-004
    Material Weakness
  • 419321 2022-004
    Material Weakness
  • 419322 2022-004
    Material Weakness
  • 419323 2022-004
    Material Weakness
  • 419324 2022-004
    Material Weakness
  • 419325 2022-004
    Material Weakness
  • 419326 2022-004
    Material Weakness
  • 419327 2022-002
    Material Weakness Repeat
  • 419328 2022-004
    Material Weakness
  • 419330 2022-001
    Material Weakness Repeat
  • 419331 2022-002
    Material Weakness Repeat
  • 419332 2022-002
    Material Weakness Repeat
  • 419333 2022-003
    - Repeat
  • 419334 2022-003
    - Repeat
  • 995751 2022-002
    Material Weakness Repeat
  • 995752 2022-004
    Material Weakness
  • 995753 2022-004
    Material Weakness
  • 995754 2022-004
    Material Weakness
  • 995755 2022-004
    Material Weakness
  • 995756 2022-004
    Material Weakness
  • 995757 2022-002
    Material Weakness Repeat
  • 995758 2022-002
    Material Weakness Repeat
  • 995759 2022-004
    Material Weakness
  • 995760 2022-002
    Material Weakness Repeat
  • 995761 2022-004
    Material Weakness
  • 995762 2022-004
    Material Weakness
  • 995763 2022-004
    Material Weakness
  • 995764 2022-004
    Material Weakness
  • 995765 2022-004
    Material Weakness
  • 995766 2022-004
    Material Weakness
  • 995767 2022-004
    Material Weakness
  • 995768 2022-004
    Material Weakness
  • 995769 2022-002
    Material Weakness Repeat
  • 995770 2022-004
    Material Weakness
  • 995771 2022-001
    Material Weakness Repeat
  • 995772 2022-001
    Material Weakness Repeat
  • 995773 2022-002
    Material Weakness Repeat
  • 995774 2022-002
    Material Weakness Repeat
  • 995775 2022-003
    - Repeat
  • 995776 2022-003
    - Repeat

Programs in Audit

ALN Program Name Expenditures
21.023 Emergency Rental Assistance Program $8.27M
21.026 Arpa- Haf Counseling Sustainability Grant $249,949
21.027 Ulms Young Adult Shelter $214,025
21.019 Coronavirus Relief Fund $124,710
17.258 Wioa Title 1b Adult Services, Career Services Program $122,043
17.259 Wioa Py21/fy22- Title 1b Youth Services, Out-of-School $110,859
16.726 Project Ready Mentor Vi $98,113
17.261 Pathways for Youth $67,615
93.185 Cdc Vaccine Equity $41,000
99.U19 Housing Stability Counseling Program $37,128
14.316 Housing Counsing Counseling Training Program $30,022
97.024 Emergency Food and Shelter Program $13,158