Finding 4875 (2022-005)

Significant Deficiency
Requirement
CL
Questioned Costs
-
Year
2022
Accepted
2023-12-16
Audit: 7039
Organization: Samu Foundation (DC)

AI Summary

  • Core Issue: Lack of documented independent review for program and financial reports, leading to potential noncompliance with federal requirements.
  • Impacted Requirements: Non-compliance with 2 CFR 200.303 and internal control standards, risking ineffective management of federal awards.
  • Recommended Follow-Up: Implement procedures for independent review and approval, ensuring documentation with signatures and dates before submission to funders.

Finding Text

Finding 2022-005: Cash Management and Reporting Criteria: Under 2 CFR 200.303, organizations that receive federal funding are required to “establish and maintain effective internal control over the Federal award that provides 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 guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: No evidence of independent secondary level of review or approval is performed relating to program reports; additionally, no evidence of review/approval for financial reports or reimbursement request could be provided. While management asserts that a review and approval of program reporting, financial reporting and reimbursement requests is taking place, there is no audit trail that shows the evidence of the control occurring. Cause: Management did not have effective internal controls in place to ensure that a secondary level of review of approval is clearly documented, which indicates who performed the control, and when the control was performed. Effect or Potential Effect: Without established controls over reporting and reimbursement requests, there is a reasonable possibility that SAMU would not detect noncompliance in the normal course of performing duties and correct them in a timely manner. Questioned Costs: None. Context: Our audit procedures consisted of testwork performed over cash receipts and draw down requests from the Federal Government as well as program reports submitted. We consider our sample to be representative of the population. The condition appears to be systemic in nature. Identification as a Repeat Finding, if Applicable: Not applicable. Recommendation: We recommend that management of SAMU implement procedures and control processes to incorporate and document an independent review and approval, evidenced by a signature/initialing and date of the review and approval taking place prior to submission to the funder.

Corrective Action Plan

Views of Responsible Officials: In 2022, narrative program reports were prepared by the management team (inputs were provided by each thematic area/department), the Deputy Director (or her designee) reviewed, and the Managing Director approved and typically sent the narrative reports to United Way via email (or in some instances, uploaded to the United Way SharePoint directly). In 2022, financial reports were prepared by CBM, reviewed by the Deputy Director (with support from a Coordinator, when possible), and sent to the Managing Director for approval and signature. The signed documents were then uploaded into the United Way SharePoint, and a note was sent to advise that the documents were ready to review. Reimbursements have never been sent to United Way without the approval and signature of the Managing Director. United Way requires that all financial reports reflect Managing Director signature to be reviewed.

Categories

Cash Management

Other Findings in this Audit

  • 4874 2022-004
    Material Weakness
  • 4876 2022-006
    Material Weakness
  • 4877 2022-007
    Material Weakness
  • 581316 2022-004
    Material Weakness
  • 581317 2022-005
    Significant Deficiency
  • 581318 2022-006
    Material Weakness
  • 581319 2022-007
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
97.024 Emergency Food and Shelter National Board Program $1.61M