ACL Centers for Independent Living – Assistance Listing No. 93.435
Type of Finding: Cash Management
• Material Weakness in Internal Control over Compliance
Criteria or specific requirement: Per 2 CFR 200.302(b)(3) the nonfederal entity must
keep "records that identify adequately the source and application of funds for federally
funded activities" and must maintain effective controls over these procedures.
Condition: No accompanying invoices to support drawdown requests.
Questioned costs: None
Context: While there existed evidence of supporting invoices for Federal expenditures
(with the exception of one item for $52 - see finding 2022-006), these were not
compiled into an auditable list showing justification for the drawdown amounts.
Auditors reviewed the profit and loss schedule for the year and were not able to identify
a clear pattern between expenditures and drawdowns.
Cause: Lack of procedures requiring supporting documentation.
Effect: Reimbursement requests could be made for unallowed expenditures.
Repeat Finding: No
Recommendation: Implement process to ensure documentation is kept identifying
which expenditures are included in reimbursement request. There should be a
secondary individual (ED and contract accountant) involved in the process to ensure
accuracy - documentation of the two-person preparation and review process should be
documented.
Views of responsible officials: There is no disagreement with the audit finding.
Action taken in response to finding: DEC’s new contract accountant provides a twolevel
review process for DEC accounting including review and documentation for
drawdowns.
Name(s) of the contact person(s) responsible for corrective action: Kimberly Meck,
Executive Director
Planned completion date for corrective action plan: Already implemented.