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."