Finding 480546 (2022-002)

Significant Deficiency
Requirement
AB
Questioned Costs
-
Year
2022
Accepted
2024-08-06

AI Summary

  • Core Issue: NIWHRC lacks proper accounting records to track federal expenditures by individual programs, leading to inaccuracies.
  • Impacted Requirements: Failure to comply with Uniform Guidance § 200.510, which mandates detailed reporting of federal awards by program.
  • Recommended Follow-Up: Implement policies for tracking federal expenditures and consider using a third-party CPA for monthly reconciliations.

Finding Text

Section III - Findings Required to be Reported in Accordance with Uniform Guidance: 2022-002 Expenditures of Federal Awards-Internal Control and Compliance- AL/CFDA #: 93.243-Federal Program: Substance Abuse and Mental Health Services Projects of Regional and National Significance-Criteria: Chapter 2, Part 200, Subpart F § 200.510 Schedule of Expenditures of Federal Awards (Uniform Guidance) states, "The Auditee must also prepare a schedule of expenditures of federal awards for the period covered by the financial statements which must include the total Federal awards expended as determined in §200.502...(3) Provide total Federal awards expended for each Federal Program..."-Condition: The NIWHRC did not keep adequate accounting records to allow for expenditures to be accumulated by the individual Federal program. All expenditures were recorded as Federal expenditures without information on which program expended the funds.- Cause and Effect: No procedure has been developed to reconcile all balance sheet accounts each month (i.e., restricted cash, utility receivables, account payables, capital assets, etc.). As a result, the balance sheet may be out of balance with the subsidiary accounts and ledgers and the Organization would not be aware of it. - Recommendation: We recommend the NIWHRC develop policy and procedures to record federal expenditures by Federal award. This could also be a function of a third-party CPA to reconcile each Federal award to ensure expenditures are recorded correctly. - Responsible Official's Response: Subsequent to the year end, NIWHRC has engaged an outside CPA firm to reconcile the accounts monthly.

Corrective Action Plan

CORRECTIVE ACTION PLAN: DEVELOP AND IMPLEMENT PROCEDURES TO MAINTAIN ADEQUATE ACCOUNTING RECORDS THAT ACCURATELY TRACK EXPENDITURES BY INDIVIDUAL FEDERAL PROGRAMS, ENSURING COMPLIANCE WITH REPORTING REQUIREMENTS AND TRANSPARANCY IN FUND UTILIZATION. 1. IMMEDIATE ASSESSMENT: CONDUCT A COMPREHENSIVE ASSESSMENT OF CURRENT ACCOUNTING PRACTICES AND RECORDS TO IDENTIFY DEFICIENCIES IN TRACKING EXPENDITURES BY FEDERAL PROGRAMS. DETERMINE THE SCOPE AND EXTENT OF INACCURACIES OR GAPS IN DOCUMENTATION. 2. ENGAGE ACCOUNTING EXPERTISE: ENGAGE A THIRD-PARTY CPA FIRM EXPERIENCED IN GOVERNMENTAL ACCOUNTING AND FEDERAL GRANT COMPLIANCE TO ASSIST IN RESOLVING THE ISSUE. 3. REVIEW FEDERAL PROGRAM REQUIREMENTS: REVIEW THE REQUIREMENTS OF EACH FEDERAL PROGRAM UNDER WHICH FUNDS ARE RECEIVED. IDENTIFY SPECIFIC REPORTING AND EXPENDITURE TRACKING REQUIREMENTS MANDATED BY EACH PROGRAM. 4. DEVELOP CHART OF ACCOUNTS: DEVELOP OR REVISE A DETAILED CHART OF ACCOUNTS THAT CLEARLY DISTINGUISHES EXPENDITURES BY EACH FEDERAL PROGRAM. ASSIGN UNIQUE CODES OR IDENTIFIERS TO TRANSACTIONS ASSOCIATED WITH EACH PROGRAM. 5. IMPLEMENT SEGREGATION OF EXPENDITURES: IMPLEMENT PROCEDURES TO SEGREGATE EXPENDITURES BY FEDERAL PROGRAM AT THE TIME OF RECORDING. ENSURE ALL TRANSACTIONS ARE ALLOCATED ACCURATELY TO THE APPROPRIATE PROGRAM BASED ON THE CHART OF ACCOUNTS. 6. DOCUMENT EXPENDITURE ALLOCATION: DOCUMENT THE ALLOCATION OF EXPENDITURES TO SPECIFIC FEDERAL PROGRAMS CLEARLY AND COMPREHENSIVELY. MAINTAIN SUPPORITNG DOCUMENTATION SUCH AS INVOICES, RECEIPTS, AND PAYROLL RECORDS THAT SUBSTANTIATE THE ALLOCATION. 7. TRAINING AND CAPACITY BUILDING: CONDUCT TRAINING SESSIONS FOR ACCOUNTING STAFF INVOLVED IN RECORDING AND REPORTING EXPENDITURES. TRAIN THEM ON THE NEW PROCEDURES, CHART OF ACCOUNTS, AND THE IMPORTANCE OF ACCURATELY TRACKING EXPENDITURES BY FEDERAL PROGRAM. 8. REGULAR RECONCILIATION AND REPORTING: IMPLEMENT A PROCESS FOR REGULAR RECONCILIATION OF EXPENDITURES WITH FEDERAL PROGRAM REQUIREMENTS. ENSURE RECONCILIATION IS PERFOMRED MONTHLY OR QUARTERLY TO IDENTIFY DISCREPANCIES PROMPTLY. 9. INTERNAL CONTROLS AND MONITORING: STREGTHEN INTERNAL CONTROLS TO PREVENT FUTURE INACCURACIES IN EXPENDITURE TRACKING. ASSIGN RESPONSIBILITY FOR OVERSIGHT AND MONITORING OF COMPLIANCE WITH THE NEW PROCEDURES. - TIMELINE FOR IMPLEMENTATION: ONGOING: MAINTAIN VIGILANCE OVER COMPLIANCE AND ADJUST AS NEEDED. - CONCLUSION: BY IMPLEMENTING THIS CORRECTIVE ACTION PLAN, WE AIM TO ESTABLISH ROBUST ACCOUNTING PRACTICES THAT ACCURATELY TRACK EXPENDITURES BY INDIVIDUAL FEDERAL PROGRAMS. THIS WILL ENSURE COMPLIANCE WITH REPORTING REQUIREMENTS, ENHANCE TRANSPARENCY IN FUND UTILIZATION, AND MITIGATE RISKS ASSOCIATED WITH INACCURATE FINANCIAL REPORTING. THIS PLAN OUTLINES OUR COMMITMENT TO ADDRESSING THE CURRENT DEFICIENCIES AND ESTABLISHING A SUSTAINABLE FRAMEWORK FOR FUTURE OPERATIONS. - RESPONSIBLE PARTY: KIMBERLEY CHAFFIN, EXECUTIVE DIRECTOR- DATE OF IMPLEMENTATION: OCTOBER 1, 2023.

Categories

Reporting Internal Control / Segregation of Duties

Other Findings in this Audit

  • 480547 2022-002
    Significant Deficiency
  • 480548 2022-002
    Significant Deficiency
  • 1056988 2022-002
    Significant Deficiency
  • 1056989 2022-002
    Significant Deficiency
  • 1056990 2022-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $416,327
93.788 Opioid Str $333,593
93.612 Native American Programs $172,326