Finding Text
Significant Deficiency in Internal Control over Compliance: Approval of Executive Director’s
Expenditures.
Information on the Federal Program: Assistance Listing Number 16.526 ‐ Office on Violence Against Women:
Training and Technical Assistance Initiative and 16.557 Office on Violence Against Women: Tribal Domestic
Violence and Sexual Assault Coalitions Program
Award Numbers: 15JOVW‐21‐GG‐02267‐MUMU, 2018‐TA‐AX‐K002
Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs and Cost Principles
Type of Finding: Significant deficiency in internal control over compliance.
Criteria: 2 CFR 200.3030 of Subpart D, “Post Federal Award Requirements Standards for Financial Program
Management,” of the Uniform Guidance requires a nonfederal entity to establish and maintain effective internal
control over the federal award that provides reasonable assurance that the entity is managing the federal award in
compliance with federal statutes, regulations, and the terms and conditions of the federal award, including
Activities Allowed or Unallowed and Allowable Costs and Cost Principles.
Condition: Processes and procedures in place to approve expenditures did not include timely approval of expenses
initiated by the Executive Director.
Cause: The Executive Director or Operations Director approves all expenditures, however a process was not in place
for a Circle Keeper (board member) to regularly review expenditures initiated by the Executive Director during 2022.
Effect or Potential Effect: Unallowable costs or activities could be charged to federal grants.
Questioned Cost: None
Context: One of eleven items selected ($252 of $23,074 direct expenses tested) for assistance listing 16.526 and
one of twenty‐four items selected ($377 of $21,809 direct expenses tested) for assistance listing 16.557 had not
been approved as of the date of testing.
Recommendation: We recommend the Organization provide evidence of the Executive Director’s expenses to a
Circle Keeper for approval on a regular basis.Responsible Official’s Response: Agree. The two expenditures initiated by the Executive Director that did not have
the required approval of the Keeper of Finances was an oversight and not in line with the Financial Policies and
Procedures. We have determined an update is necessary to the procedures in the Financial Policies and Procedures
manual to address the use of MIWSAC credit/debit cards for expenditures. We have updated Part III, Sections 2 and
4, which is included with the corrective action.
Further, we will request the Circle Keepers to adopt these changes to the Financial Policies and Procedures at their
next scheduled meeting. And, we will advise staff of the expense approval oversights revealed by the audit along
with the updated procedures added to the Financial Policies and Procedures manual. This communication will be
provided in writing as a memo to all staff.