Finding Text
2023-001 – REPORTING- ARPA GRANT Type of Finding: (F) –Significant Deficiency in Internal Control Over Compliance of Federal Awards Funding Agency: National Endowment for the Humanities Title: Humanities Councils American Rescue Plan Funding (COVID-19 American Rescue Plan - Promotion of the Humanities - Federal/State Partnership) AL #: 45.129 Award #: ZSO-283159-21 ARP Award Period: November 1, 2021 – April 30, 2023. Questioned Costs: None Statement of Condition
NMHC did not have adequate controls over the SF-425. The data in SF-425 financial report for the reporting period end date of April 30, 2023 did not agree to the NMHC’s accounting records. Management’s review of the report did not identify that the amounts reported under line 10(c) (cash on hand) were understated by $35,126 as of April 30, 2023. Additionally, 2 checks with unspent funds were received from subgrantees in the amount of $6,985 after the due date of the report, bringing the total amount to be returned to the grantor to $42,111. (The subrecipients, due to deficiencies in their own internal controls, had attested in writing at the time of the closing of their grants that they had spent their total subawarded ARPA dollars in an appropriate fashion.) Criteria
In accordance with 24 CFR Part 85.41, the Federal Financial Report (SF-425) is required to be submitted for the Promotion of the Humanities - Federal/State Partnership (ARP) program. Recipients use the SF-425 as a standardized format to report expenditures under Federal awards, as well as, when applicable, cash status. Recipients are required to report both cash management information on lines 10(a) through 10(c) and financial status information on lines 10(d) through 10(o). In addition, 2 CFR Part 200.303 requires the program to establish and maintain effective internal controls over Federal awards that provides reasonable assurance of compliance with Federal statutes, regulations, and the terms and conditions of Federal awards. Cause
NMHC did not properly report cash on hand and the reviewer did not detect these errors or errors in the amounts due to be returned. The grant was not consistently tracked in the accounting system, making it hard to produce meaningful reports that could give accurate numbers for the report. Effect
Weaknesses in internal controls related to the reporting requirements could result in sanctions by the National Endowment for the Humanities. Questioned costs are not applicable to this finding. Recommendation
NMHC staff should perform more detailed reviews of the reports to ensure they properly reflect grant receipts and expenditures. The accounting records should track all revenue and expenses by grant to be able to perform timely and accurate reconciliation. This review should be performed by someone other than the preparer and should include documented evidence of agreeing the reported data to the accounting records. We further recommend training for those individuals involved in the preparation and review of the reports to ensure they are fully aware of the requirements. View of Responsible Official and Corrective Action Plan:
NMHC management will perform more detailed reviews of future SF-425 forms to ensure they accurately reflect grant receipts and expenditures. NMHC ‘s Executive Director has already ensured that accounting records track all revenue and expenses by grant in order to be able to perform timely and accurate reconciliation through more regular reviews. The Executive Director will seek further training to ensure they are fully aware of the requirements.
NMHC will quickly return to the National Endowment for the Humanities the understated amount, deemed to be $42,111. The NMHC Financial Officer will amend the current SF-425 for the NEH ARPA grant and the Executive Director will submit it to the NEH Office of Grant Management. Corrective Action Plan Timeline:
Management anticipates the above corrective action plan to be fully implemented by July 31, 2024. Designation Of Employee Position Responsible For Meeting Deadline:
The Executive Director will be responsible for ensuring implementation.