ACL Centers for Independent Living – Assistance Listing No. 93.435
Type of Finding: Allowable Activities and Allowable Costs – General Disbursements
• Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: Per 2 CFR 200.303, non-Federal entities must 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 statues regulations, and the terms and conditions of the Federal award.
Condition: Documentation not maintained to support one cash disbursement.
Questioned costs: None
Context: 1/40 of the general disbursements tested lacked indication of approval.
Deemed to be an isolated incident as the vendor in question provides physical receipts
to DEC, which is an unusual and infrequent method. Limited transactions with said
vendor.
Cause: Vendor purchases are in-person and physical receipt is obtained. This is unusual
for common vendors used and leads to more opportunity for documentation loss.
Effect: Reimbursement requests could be made for unallowed expenditures.
Repeat Finding: No
Recommendation: Review document retention process to ensure all costs that are
charged to a federal program are adequately reviewed and documentation of that
process is maintained. If documentation is not available, costs should not be charged to
the Federal program.
Views of responsible officials: There is no disagreement with the audit finding.
Action taken in response to finding: This was an isolated incident and DEC now takes
steps to digitally record physical receipts with a photograph as soon as possible.
Name(s) of the contact person(s) responsible for corrective action: Kimberly Meck,
Executive Director
Planned completion date for corrective action plan: Already implemented.