FAC Explorer

Finding 505524 (2022-004)

Significant Deficiency
Requirement
P
Questioned Costs
-
Year
2022
Accepted
2024-11-13
Audit: 328235
Organization: Knoxville Knox County Community Action Committee (TN)
Auditor: Pya PC

AI Summary

  • Core Issue: CAC lacks written procedures for internal controls over federal awards, particularly for eligibility determination and reporting requirements.
  • Impacted Requirements: This non-compliance with 2 CFR section 200.303 increases the risk of errors in managing federal awards.
  • Recommended Follow-Up: Management should create and document clear procedures for eligibility and reporting to ensure compliance and reduce risks.

Finding Text

Criteria: 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statues, regulations, and the terms and conditions of the federal awards. Condition: CAC has a documented management services manual that states: "Post award procedures-after an award has been made to CAC, the following steps take place: verify the specifications of the grant or contract. The Management Services Department shall review the terms time periods, award amounts and expected expenditures with the award...All reporting requirements under the contract shall be summarized." Additionally, CAC does not have written entity wide or program specific procedures and internal controls for determining eligibility for federal award programs. Cause: The Auditor requested a copy of the summarized reporting requirements, by each Major Program, with reporting identified as a direct and material compliance requirement. Reporting summaries were not prepared as indicated in the written control procedure and available upon request. The Auditor requested a copy of the entity wide and program specific internal controls over compliance for the determination of eligibility for each Major Program with eligibility identified as a direct and material compliance requirement. CAC was not able to provide documented controls for eligibility when requested. Effect: Not having written policies or procedures detailing control activities supporting compliance with eligibility requirements or following activities prescribed for reporting, increases the risk for potential errors and indicates CAC's need to bolster and adequately document internal control. Recommendation: CAC management should ensure all reporting requirements documented in awards contracts are summarized and entity wide or program specific procedures and internal controls for determining eligibility for federal award programs are in writing and easily accessible. Views of Responsible Official(s) and Planned Corrective Actions: See the accompanying "Management's Corrective Action Plan."

Corrective Action Plan

We agree that CAC did not summarize agency wide or program specific internal controls and reporting requirements as required by 2CFR 200.303 and the CAC Management Services Manual. In order to ensure that the reporting requirements and specific internal controls of all awards made to CAC are summarized in adherence to 2 CFR 200.303 and the CAC Management Services Manual, the following corrective action will be implemented: Beginning in the FY2025 fiscal year, CAC will add a senior level staff position designated as Director of Compliance. The Director of Compliance will review and update current policies and procedures regarding specific internal controls, compliance reporting and eligibility for all awards received by CAC. The Director of Compliance will work with the Chief Program Officer and the Chief Financial Officer to ensure the development and application of program specific procedures and internal controls for reporting and determining eligibility for federal award programs. The projected date for full implementation of the corrective action plan for this finding is June 30, 2025. The contact persons for this corrective action are: Barbara Kelly, Executive Director, Windie Wilson, CAC Human Resources Director, Misty Goodwin, CAC Chief Program Officer, David Mincey, CAC Fiscal Services Manager/Internal Auditor, CAC Director of Compliance, to be selected.

Categories

Eligibility Reporting Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 505525 2022-004
    Significant Deficiency
  • 505526 2022-004
    Significant Deficiency
  • 505527 2022-004
    Significant Deficiency
  • 505528 2022-004
    Significant Deficiency
  • 505529 2022-004
    Significant Deficiency
  • 505530 2022-004
    Significant Deficiency
  • 505531 2022-004
    Significant Deficiency
  • 505532 2022-004
    Significant Deficiency
  • 505533 2022-004
    Significant Deficiency
  • 505534 2022-004
    Significant Deficiency
  • 505535 2022-004
    Significant Deficiency
  • 505536 2022-004
    Significant Deficiency
  • 505537 2022-004
    Significant Deficiency
  • 505538 2022-004
    Significant Deficiency
  • 505539 2022-004
    Significant Deficiency
  • 505540 2022-004
    Significant Deficiency
  • 505541 2022-004
    Significant Deficiency
  • 505542 2022-004
    Significant Deficiency
  • 505543 2022-004
    Significant Deficiency
  • 505544 2022-004
    Significant Deficiency
  • 505545 2022-005
    Significant Deficiency
  • 505546 2022-006
    Significant Deficiency
  • 505547 2022-006
    Significant Deficiency
  • 505548 2022-006
    Significant Deficiency
  • 505549 2022-006
    Significant Deficiency
  • 505550 2022-006
    Significant Deficiency
  • 505551 2022-006
    Significant Deficiency
  • 505552 2022-006
    Significant Deficiency
  • 505553 2022-006
    Significant Deficiency
  • 1081966 2022-004
    Significant Deficiency
  • 1081967 2022-004
    Significant Deficiency
  • 1081968 2022-004
    Significant Deficiency
  • 1081969 2022-004
    Significant Deficiency
  • 1081970 2022-004
    Significant Deficiency
  • 1081971 2022-004
    Significant Deficiency
  • 1081972 2022-004
    Significant Deficiency
  • 1081973 2022-004
    Significant Deficiency
  • 1081974 2022-004
    Significant Deficiency
  • 1081975 2022-004
    Significant Deficiency
  • 1081976 2022-004
    Significant Deficiency
  • 1081977 2022-004
    Significant Deficiency
  • 1081978 2022-004
    Significant Deficiency
  • 1081979 2022-004
    Significant Deficiency
  • 1081980 2022-004
    Significant Deficiency
  • 1081981 2022-004
    Significant Deficiency
  • 1081982 2022-004
    Significant Deficiency
  • 1081983 2022-004
    Significant Deficiency
  • 1081984 2022-004
    Significant Deficiency
  • 1081985 2022-004
    Significant Deficiency
  • 1081986 2022-004
    Significant Deficiency
  • 1081987 2022-005
    Significant Deficiency
  • 1081988 2022-006
    Significant Deficiency
  • 1081989 2022-006
    Significant Deficiency
  • 1081990 2022-006
    Significant Deficiency
  • 1081991 2022-006
    Significant Deficiency
  • 1081992 2022-006
    Significant Deficiency
  • 1081993 2022-006
    Significant Deficiency
  • 1081994 2022-006
    Significant Deficiency
  • 1081995 2022-006
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.600 U.s. Department of Health & Human Services Direct Programs $1.06M
21.023 U.s. Department of the Treasury $922,362
14.900 U.s. Department of Housing & Urban Development $618,999
94.006 U.s. Department of Labor $610,706
20.507 U.s. Department of Transportation $455,572
17.235 U.s. Department of Labor $423,080
94.011 U.s. Department of Labor $375,771
93.569 U.s. Department of Health & Human Services Direct Programs $363,617
93.045 U.s. Department of Health & Human Services Direct Programs $313,878
94.016 U.s. Department of Labor $289,875
17.278 U.s. Department of Labor $282,438
14.231 U.s. Department of Housing & Urban Development $277,806
81.042 U.s. Department of Energy $253,531
21.027 U.s. Department of the Treasury $230,477
16.575 U.s. Department of Justice $185,685
93.053 U.s. Department of Health & Human Services Direct Programs $154,431
15.944 U.s. Department of Interior $102,539
93.568 U.s. Department of Health & Human Services Direct Programs $101,479
93.558 U.s. Department of Health & Human Services Direct Programs $96,359
14.267 U.s. Department of Housing & Urban Development Direct Program $81,080
10.558 U.s. Department of Agriculture $73,399
94.002 U.s. Department of Labor $72,100
10.568 U.s. Department of Agriculture $61,417
93.667 U.s. Department of Health & Human Services Direct Programs $61,083
14.218 U.s. Department of Housing & Urban Development $39,801
20.513 U.s. Department of Transportation $37,997
93.052 U.s. Department of Health & Human Services Direct Programs $32,419
94.013 U.s. Department of Labor $29,803
10.559 U.s. Department of Agriculture $20,422
21.009 U.s. Department of the Treasury $20,000
17.258 U.s. Department of Labor $13,494
93.044 U.s. Department of Health & Human Services Direct Programs $12,464
93.779 U.s. Department of Health & Human Services Direct Programs $10,000
97.024 U.s. Federal Emergency Management Agency $2,387