Finding 498148 (2023-001)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
$1
Year
2023
Accepted
2024-09-25

AI Summary

  • Core Issue: The Schedule of Expenditures of Federal Awards (SEFA) was incorrectly prepared, using budget billings instead of actual expenditures.
  • Impacted Requirements: This violates Uniform Guidance, which mandates accurate reporting of federal awards, including the Assistance Listing Number (ALN).
  • Recommended Follow-Up: Management should create clear policies and procedures to ensure all allowable grant expenditures are accurately reported on the SEFA.

Finding Text

Criteria: “A non-Federal entity that expends $750,000 or more in Federal awards during the non-Federal entity's fiscal year must have a single or program-specific audit conducted for that year in accordance with the provisions of the Uniform Guidance Part 2 CFR section 200.50 (a). In order to accomplish this, “The auditee must also prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee's financial statements which must include the total Federal awards expended as determined in accordance with § 200.502” per Part 2 CFR section 200.510 (b) of the Uniform Guidance. This guidance includes the requirement that the SEFA include the Assistance Listing Number (ALN) for each grant award included in the schedule . Condition: The amounts recorded as federal expenditures on the SEFA were not based on expenditures. The amounts recorded as expenditures and recognized as revenues were based on budget billings. Cause: Prior management lacked an understanding of what should be considered a grant (versus a contract) and how expenditures should be determined. Effect: The SEFA was not prepared correctly, which could have a direct and material effect on allowable costs, the financial statements, and annual audit. Questioned Costs: Expenditures on the SEFA are recorded on an incorrect basis and per finding 2023-003, were not properly supported. The major program, ALN 84.027 reported expenditures of $840,000. Although not tested as a major program, we determined for the same reason noted in this finding that the other federal reported expenditures on the SEFA are also considered questioned cost, totaling $508,600. Context: Federal programs and expenditures are not recognized consistent with the Uniform Guidance. Identification of Repeat Finding: 2020-001, 2021-001, 2022-001 Recommendation: We recommend that management develop policies and procedures to ensure all allowable grant expenditures are included on the SEFA and are accumulated, and recognized on the appropriate basis.

Corrective Action Plan

To address the identified weaknesses and strengthen internal controls over the preparation of the SEFA, management has initiated the following actions: 1. Establishment of Formal Policies and Procedures: We have developed and implemented a formal, written policy for the preparation and review of the SEFA. This policy outlines clear roles, responsibilities, and timelines for all departments involved in the process. 2. Centralization of Data Collection: We are centralizing the process of collecting expenditure data, which will be overseen by a designated team within the fiscal department. This will ensure consistency and accuracy in reporting across all departments. 3. Staff Training and Development: Key personnel involved in SEFA preparation are undergoing specialized training on federal, state, and city compliance requirements. This includes training on the proper classification of awards and expenditures. 4. Internal Review and Monitoring: A second layer of review has been introduced to verify the accuracy and completeness of the SEFA before it is submitted. A senior financial officer will perform this review, ensuring that any discrepancies are identified and corrected before submission. Management will implement ongoing monitoring to ensure adherence to the new policies and procedures. Quarterly reviews will be conducted to assess the accuracy of the data and the efficiency of the control measures. Management is committed to maintaining robust internal controls over the preparation of the SEFA to ensure the timely and accurate reporting of federal, state, and city awards. The actions outlined above are designed to prevent the recurrence of this deficiency and ensure full compliance with regulatory requirements.

Categories

Questioned Costs Reporting Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 498149 2023-002
    - Repeat
  • 498150 2023-003
    Material Weakness Repeat
  • 1074590 2023-001
    Material Weakness Repeat
  • 1074591 2023-002
    - Repeat
  • 1074592 2023-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.027 Special Education Grants to States $840,000
93.558 Temporary Assistance for Needy Families $418,903
93.667 Social Services Block Grant $244,472
93.071 Medicare Enrollment Assistance Program $58,868