Finding 2023-002: Reportable Finding Considered a Significant Deficiency – Reporting
Assistance Listing Number: 10.181
Agency: U.S. Department of Agriculture
Program: Pandemic Relief Activities: Farm and Food Worker Relief Program (FFWR)
Award Number: AM22FFWDC0002-02
Grant Years: 2023
Views of Responsible Officials –
We acknowledge the finding regarding the reconciliation of Form SF-425 for the period November 4, 2022, through April 3, 2023. The issue arose because the preparer did not properly reconcile financial records or obtain a secondary review prior to submission. We are committed to maintaining compliance with 2 CFR sections 200.328 and 200.329 and have already taken corrective steps.
Corrective Actions –
Root Cause Analysis: The deficiency was caused by the preparer’s failure to review and reconcile Form SF-425 with the financial records prior to submission. The preparer submitted the form without verifying the accuracy of the data.
Revised Reporting and Review Process:
• Action: We have implemented a formal review process where all Forms SF-425 are reconciled with the financial records before submission. This process includes:
o The preparer reconciles the financial data with the underlying financial records.
o A mandatory review by the Finance Director or another senior finance officer before submission.
o Final approval is given by the Program Director and then the President.
• Results: This process was successfully implemented for the April 4, 2023, through October 3, 2023, filing, significantly improving accuracy and compliance.
• Responsible Person: The Finance Director is responsible for overseeing the reconciliation and review process.
• Timeline: The new process is already in place and was followed for the second filing in 2023.
Documentation of Review and Approval:
• Action: All review and approval process steps are documented through email communications, ensuring that each step—from reconciliation to final approval—is tracked and recorded.
• Responsible Person: The Finance Director ensures that email approvals are completed and stored as part of the official documentation.
• Timeline: This documentation process is currently in place and was followed for the April 4, 2023, through October 3, 2023, submission.
Conclusion:
The corrective actions outlined above have been implemented and are already showing positive results, as demonstrated by the successful filing of the April 4, 2023, through October 3, 2023, From SF-425. By ensuring that every Form SF-425 is reconciled and reviewed before submission, we are confident that these measures will prevent future discrepancies.
Completion Timeline:
The revised review and approval process is fully implemented and has been successfully applied to the April 4, 2023, through October 3, 2023, filing.